News & Analysis as of

Tax Evasion Compliance

Holland & Knight LLP

Treasury Department Confirms Suspension of U.S.-Russia Income Tax Treaty

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The U.S. Department of the Treasury on June 17, 2024, confirmed it had formally notified Russia about the suspension of the Convention between the United States of America and the Russian Federation for the Avoidance of...more

WilmerHale

UK Criminal Enforcement Update - Spring 2024

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Recent weeks have seen several notable developments in the UK criminal enforcement landscape...more

Whitman Legal Solutions, LLC

Court Decision Doesn’t Affect Corporate Transparency Act Requirements for Most Companies and Real Estate Investors

On March 1, 2024 a United States District Court in Alabama held in National Small Business United dba National Small Business Association v. Yellen (NSBA Case) that the Corporate Transparency Act (CTA) is unconstitutional. ...more

Womble Bond Dickinson

Navigating the Labyrinth: Artificial Intelligence in the Battle Against Trade-Based Money Laundering

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In the rapidly evolving financial landscape, governments worldwide are intensifying their focus on compliance in Know Your Customer (KYC) and Anti-Money Laundering (AML) efforts for financial institutions. Trade-Based Money...more

A&O Shearman

Higher tax related money laundering risks for financial institutions

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Financial institutions and other AML-obliged entities in Belgium now face increased criminal risks for laundering the proceeds of any type of tax fraud. Higher money laundering risks...more

Rivkin Radler LLP

Self-Employment Tax and the Limited Partner – Substance Over Form, or Something Else?

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Last week, the IRS announced “the start of a sweeping, historic effort to restore fairness in tax compliance by shifting more attention onto high-income earners, partnerships, large corporations and promoters abusing the...more

Cole Schotz

Important Supreme Court Decision will Decide how Non-Willful FBAR Penalties are Calculated

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This fall, the Supreme Court is set to hear an important case regarding the interpretation of the law that provides for penalties for failing to file an FBAR. The case will impact many taxpayers who have already been...more

American Conference Institute (ACI)

[Event] Mexico Summit on Anti-Corruption & Compliance Programs - March 22nd - 23rd, Mexico City, Mexico

Join the Go-To Event of the Year for Mexico’s Anti-Corruption Community. The annual ACI’s Anti-Corruption Summit in Mexico is back to Mexico City on March 22-23, 2022! This is the most important anti-corruption compliance...more

Dechert LLP

The Pandora Papers and the Heightened Importance of “Knowing Your Customer”

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Key Takeaways - On October 3, 2021, the International Consortium of Investigative Journalists released the “Pandora Papers,” which expose the use by political leaders, billionaires, and others of offshore entities in an...more

Skadden, Arps, Slate, Meagher & Flom LLP

Impact of COVID-19 on White Collar Enforcement

While enforcement agencies have yet to indicate that they intend to put their pens down in response to COVID-19, there is anecdotal evidence that some agencies have slowed their investigations as remote working impacts matter...more

McDermott Will & Emery

How CCO Reasonable Prevention Procedures Can Help You Mitigate DAC6 Penalties

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Corporate criminal offences (CCOs) under Part 3 Criminal Finances Act 2017 (CFA) are increasingly coming under the spotlight of the UK tax authorities. In a 10 February 2020 press release published in response to a Freedom of...more

BCLP

Failure to prevent tax evasion – HMRC announces 9 live investigations and 21 “opportunities under review”

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HMRC’s focus on organisations under the Criminal Finances Act 2017 for failure to prevent tax evasion is making steady progress. The revelation, in very broad terms, of the number of investigations and enquires that it is...more

Thomas Fox - Compliance Evangelist

The Ahsani’s Information – Final Thoughts

This week I have been considering the guilty pleas of the former Unaoil Chief Executive Officer (CEO), Cyrus Ahsani, and former Chief Operations Officer (COO), Saman Ahsani, as was laid out in their Information. Most...more

Skadden, Arps, Slate, Meagher & Flom LLP

Cross-Border Investigations Update - September 2019

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including a review of the first year of GDPR enforcement, analysis of...more

Rosenberg Martin Greenberg LLP

What are some of the monetary penalties and other consequences of failing to properly report my foreign real estate and other...

Depending upon how foreign real estate is owned and/or controlled, a number of different tax reporting regimes may be implicated.  Each of these has its own corresponding penalties and generally applies to United States...more

White & Case LLP

Does your compliance program address UK exposure?

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Tech companies of U.S. origin tend to have compliance programs focused on U.S. laws, including the Foreign Corrupt Practices Act (the "FCPA") and relevant tax and labor laws. The UK has enacted laws covering bribery and...more

Skadden, Arps, Slate, Meagher & Flom LLP

France Announces Its First Deferred Prosecution Agreement

In a move that could signal a new phase of government enforcement in France, on November 27, 2017, French authorities published a Convention judiciaire d’intérêt public (CJIP) with HSBC Private Bank Suisse SA (HSBC PB), the...more

WilmerHale

The failure to prevent tax evasion

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The Criminal Finances Act 2017 (“the Act”)1 came into force on 30 September 2017. The Act contains a patchwork of new powers, and amendments to existing legislation, largely directed at combatting money laundering and...more

Dorsey & Whitney LLP

Anti-Corruption Digest - July 2017

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Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. The Digest puts material regarding anti-corruption enforcement from around the world at your fingertips, keeping you ahead of critical events that impact global...more

Thomas Fox - Compliance Evangelist

The Panama Papers and Shell Games, Part I

One of the more prescient authors I know is Ryan C. Hubbs, a senior manager of fraud investigation and dispute services at Ernst & Young LLP (EY), who, in 2014, wrote an article for Fraud Magazine entitled “Shell Games”. In...more

Thomas Fox - Compliance Evangelist

What Can You Learn in the First Inning?

You might figure that the year I decide to jump back on the Houston Astros bandwagon, they go back in the tank. Last year they were one game away from the American League (AL) Championship. This year they have the third worst...more

McDermott Will & Emery

International News: Focus on Compliance

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In This Issue - Welcome to the final issue of International News for 2014. As regulatory oversight of companies—from Sarbanes Oxley and the Dodd-Frank Act to the Foreign Corrupt Practices Act and the UK Bribery...more

Blank Rome LLP

Offshore Tax Enforcement Update: IRS Unveils Major Changes to Voluntary Disclosure Program

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Since the 1970s, U.S. taxpayers with foreign banks accounts have been required to annually report their foreign bank account information to the Department of Treasury on a Report of Foreign Bank and Financial Accounts...more

Blank Rome LLP

IRS Commissioner Hints That OVDP Modifications Are in the Works

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Since 2009, the Internal Revenue Service has offered three different amnesty programs for taxpayers with undeclared foreign bank accounts. These programs, the current version of which is entitled the Offshore Voluntary...more

Blank Rome LLP

FBAR Penalty to Face Excessive Fines Clause Test

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Last week, a federal jury in Miami found that Carl Zwerner had willfully failed to disclose his foreign bank account to the Treasury Department for calendar years 2004, 2005 and 2006. Zwerner now potentially owes the United...more

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