Tax Evasion

News & Analysis as of

DOJ’s Latest Offshore Tax Case Shows Expatriates Who Renounce U.S. Citizenship Not Immune From Prosecution

An individual residing in Switzerland since 2007, who apparently renounced his U.S. citizenship four years ago, was convicted today in federal court of one count of filing a false U.S. income tax return. According to a...more

Singapore’s Income Tax (Amendment) Bill 2016

Upcoming changes to the Exchange of Information framework hints at future adoption of the Organisation for Economic Co-operation and Development’s Common Reporting Standards. The crux of Singapore’s Income Tax...more

Justice Department Announces Historic Conclusion of Swiss Bank Program for Category 2 Institutions

The Justice Department achieved a historic milestone in its ground-breaking Swiss Bank Program with its announcement today of the final Category 2 bank resolution. The Justice Department executed its 80th and final agreement...more

Cash for Scalps: Governor Cuomo Announces New Round of Grants for Tax Prosecutions

Last week, Governor Cuomo announced the latest round of grants to district attorneys’ offices in 29 New York State counties under the Crimes Against Revenue Program (also known as “CARP”). The program provides substantial...more

Global Tax Enforcement in 2016: What You Need to Know

The investigation and prosecution of tax evasion has, in the past decade, grown from a specialized subcategory of law enforcement into a first-tier policy concern for the international community. Financial institutions,...more

Cross-Border Investigations Update - November 2015

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases and enforcement trends, including developments in U.S. Foreign Corrupt Practices Act enforcement; the introduction of...more

Just when you thought it was safe to go back in the water…

The UK Government recently announced that it has shelved its plan to introduce a new corporate criminal offence for failing to prevent economic crime. However, corporates should still beware other potential criminal...more

Tax Evasion Vs. Tax Planning/Avoidance: Knowing The Difference Is Important

Last time, we began speaking about recent recommendations made by an international organization regarding tax avoidance which will reportedly make it harder for businesses to take advantage of tax law. As we noted, the...more

Offshore Accounts Still Focus of IRS Enforcement

The following Notice from the IRS reiterates the enforcement focus on offshore accounts. Anyone with an unreported offshore account needs to consult counsel and discuss, their compliance options under the "attorney-client...more

Internal Revenue Service Issues Stern Warning To Non-Compliant Taxpayers With Offshore Holdings

Just one day after the October 15 deadline for filing personal income tax returns on extension, the Internal Revenue Service issued a strongly-worded warning to non-compliant taxpayers: take action now to fix your problem, or...more

Justice Department Focusing on Offshore Account

At a recent tax conference a senior Justice Department official reaffirmed the commitment of the U.S. Department of Justice to continue offshore enforcement efforts. As is widely reported the official stated...more

Internal Revenue Service Begins Reciprocal Automatic Exchange of Tax Information Under FATCA IGAs

On October 2, 2015, the Internal Revenue Service announced that it had achieved a key milestone in implementation of the Foreign Account Tax Compliance Act (FATCA), a critical anti-tax evasion law passed by Congress in 2010...more

Global Tax News: Belgium Adopts New Fiscal Measures

The Belgian Parliament has adopted a Program Law containing a wide array of fiscal measures. The most salient of these measures are (i) the introduction of a transparency tax regime for physical and legal persons subject to...more

Bad Bad, Bad Penalty, Bad OVDP Policy

There are now 50 foreign financial institutions on the IRS list of "bad banks" The list is published at the following link...more

Focus on Tax Controversy and Litigation - United States Tax Court Invalidated Treasury Regulation § 1.482-7(d)(2)

In addition to the discussion of the Tax Court’s decision in Altera, this month’s issue features articles regarding Notice 2015-47 “Basket Options” and Notice 2015-48 “Basket Contracts”, the Federal Circuit Court of Appeals...more

Check Cashing, Tax Evasion, Structuring and Asset Forfeiture; The Making of a Bad Day

The following fact pattern should is representative of a tax evasion and structuring case. A taxpayer receives checks in the ordinary course of business from customers. Some of those checks are deposited into the business...more

Swiss Banks Bank Zweiplus and Banca Stato Have Entered into Non-Prosecution Agreements under the DOJ’s Swiss Bank Program

Two more Swiss banks have reached resolutions with the Justice Department under its Swiss Bank Program. Yesterday, DOJ announced that bank zweiplus ag (Bank Zweiplus) and Banca dello Stato del Cantone Ticino (Banca Stato)...more

INTERPOL and the tax man

A reader recently sent in the following questions: Can you tell me would the IRS issue a diffusion notice in a civil tax audit involving offshore banking? Would Interpol even accept a diffusion notice on a non criminal...more

Three More Swiss Banks Resolve Their Tax Issues with the United States

The Justice Department continues to announce resolutions with banks under its previously-announced Swiss Bank Program. On August 6, DOJ announced the names of three more Swiss banks receiving non-prosecution agreements:...more

Whose Intent to Evade Tax Is It?

On July 29, 2015, the Federal Circuit, rejecting the Tax Court’s decision in Allen v. Commissioner, 128 T.C. 37 (2007), held in BASR Partnership v. United States, No. 2014-5037, that section 6501(c)’s suspension of the...more

Does the Government Have Carte Blanche to Retain Seized Data Indefinitely? In Amicus Brief to the Second Circuit, Policy Groups...

On July 29, 2015, BakerHostetler filed an amicus brief with the Second Circuit on behalf of the Center for Democracy and Technology, joined by five prominent nonprofit public interest groups, for the en banc rehearing of...more

Justice Department Announces That Three More Swiss Banks Reach Agreements Over Tax Evasion Claims

On July 30, 2015, the Justice Department’s Tax Division announced that three more Swiss banks — PKB Privatbank AG, Falcon Private Bank AG and Credito Privato Commerciale in liquidazione SA (CPC) – have cut deals with the U.S....more

Domestic Voluntary Disclosure as an Alternative to Indictment

The United States Attorney for the Southern District of New York announced that the - "Owner and operator of DNS Construction Corporation, was sentenced today in Manhattan federal court to a term of five years of...more

Two More Banks Reach Resolutions Under Justice Department’s Swiss Bank Program

On June 3, 2015, the Justice Department announced that two more Swiss banks, Rothschild Bank AG and Banca Credinvest SA, reached resolutions under the DOJ Swiss Bank Program. Yesterday’s announcement brings the total Swiss...more

Global Tax Enforcement in 2015: What You Need to Know

Tax fraud occurs on a considerable scale that can exceed law enforcement’s ability to detect and punish the conduct. This is true at both the federal and state levels. As of 2015, the Internal Revenue Service (“IRS”) and the...more

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