The IRS and the Justice Department have increased their efforts regarding criminal investigation of international tax evasion. ...more
On February 1, 2013, the U.S. District Court for the Eastern District of Wisconsin sentenced Arvind Ahuja, a Milwaukee neurosurgeon, to serve three years of probation and to pay a fine of $350,000 following his conviction by...more
The IRS continues to aggressively pursue offshore tax evasion. Another example of which is plan to share tax information with Australia and the United Kingdom....more
There has been much publicity regarding tax avoidance of late in the UK. In the age of austerity, tax avoidance by companies is scruitnised by the press and is a hot topic with the public....more
A New York federal grand jury recently indicted a Swiss lawyer and bank executive for their roles in allegedly assisting US citizens with hiding assets in Swiss bank accounts, allowing the US citizens to evade income taxes....more
79 year-old Mary Estelle Curran received good new when she was sentenced for criminal tax evasion and failing to file reports of foreign bank accounts on UBS Swiss accounts she inherited from her husband....more
In this issue: - NFA Amends CPO and CTA Quarterly Reporting Requirements - SDNY Imposes Second Highest Penalty Under Foreign Corrupt Practices Act - Grand Jury Indicts Swiss Lawyer and Banker in Tax...more
U.S. Funds with Only U.S. Investors - FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers, will go into effect on January 1, 2014. As a fund manager, you will be required to ensure...more
Argentina signs the OECD Convention, but it does not obtain automatic access to financial information. On September 13, 2012, the Organization for Economic Co-operation and Development (OECD) announced that Argentina...more
On January 17, 2013, the Internal Revenue Service (“IRS”) released final regulations (the “Final Regulations”) implementing the reporting and withholding provisions of the HIRE Act (commonly known as the Foreign Account Tax...more
In December, Bank Leumi le-Israel BM issued a letter notifying its U.S. account holders about the IRS Offshore Voluntary Disclosure Initiative (the OVDI). The IRS OVDI is a type of amnesty program under which U.S. citizens...more
In what is clearly the first of many to come intergovernmental agreements similar to the Foreign Account Tax Compliance Acct (FATCA) adopted by the U.S. in 2010, the governments of Switzerland and the United Kingdom entered...more
UK government supports businesses, focusing on the UK's competitiveness while clamping down on tax avoidance and evasion. On 20 March, UK Chancellor of the Exchequer George Osborne released the UK's 2013 budget. The...more
As has been widely reported, the United States District Court for the Southern District of New York sentenced Wegelin & Co, the oldest Swiss private bank, to pay an additional $58 million after it admitted to helping wealthy...more
The Internal Revenue Service has had success encouraging taxpayers with offshore accounts to disclose their foreign accounts and pay back taxes. In 2009 and 2011, the IRS announced the Offshore Voluntary Disclosure Program...more
“Sometimes for taxpayers, who have serious tax non-compliance issues or may be facing international tax enforcement, the option of initiating a state voluntary disclosure contemporaneously with the making of a federal...more
The Fifth Amendment dictates that no person "shall be compelled in any criminal case to be a witness against himself." While most non-lawyers (and many lawyers) might assume that this simple edict means the government cannot...more
Recently, two Israeli banks are reported to have agreed to cooperate in criminal tax investigations being conducted by the Criminal Tax Division of the U.S. Department of Justice. The specific actions allegedly involve a...more
On January 17, 2013, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) released long-awaited final regulations on the set of statutory rules commonly referred to as FATCA. As more fully described in...more
On January 3, 2013, the United States Attorneys Office for the Southern District of New York announced that Switzerlands oldest bank, Wegelin & Co. (“Wegelin”), has pled guilty “to conspiring with U.S. taxpayers and others to...more
Five partners at Ernst & Young - Robert Coplan, Martin Nissenbaum, Richard Shapiro, and Brian Vaughn, and Charles Bolton - were charged with a number of tax crimes in federal court in New York, specifically tax evasion,...more
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