News & Analysis as of

Put Another Notch in the DOJ Gun

In the history of the old west when gun fighters survived a gun fight they might put a “notch” in their pistol as a badge of honor. Well the U.S. Department of Justice can put another notch in its weapon of choice, threat of...more

"Latest Swiss Cross-Border Tax Investigation Reflects Wider US Enforcement Agenda"

Authorities in the U.S. continue to crack down on foreign financial institutions that have allegedly aided U.S. taxpayers in evading their tax obligations. On May 19, 2014, Credit Suisse AG pled guilty to conspiracy to aid...more

Former Head of DOJ Tax Division Warns Taxpayers to Think Twice Before Choosing New Streamlined Procedures

Former DOJ Tax Division AAG Kathy Keneally warned on June 24, 2014, that taxpayers should think carefully before signing a certification of non-willfulness and entering the IRS’s new Streamlined Filing Compliance Procedures....more

The Credit Suisse Case: Did the Justice Department Lose its Nerve?

As the old adage goes, appearances can be deceiving. Sometimes when you peel back the layers on an issue, you find out that everyone, even the Justice Department, can engage in “spin.”...more

FinCrimes Update - Volume 1, Issue 3

On May 8, OFAC released enforcement information regarding “apparent violations” of the Cuban Assets Control Regulations by Canadian subsidiaries of a U.S. insurance company. The U.S. company self-reported 3,560 apparent...more

DOJ Issues Further Guidance on Swiss Bank Program

Recently the Justice Department’s Tax Division issued further “comments” regarding its “Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks.” In prior posts we have described this program designed to...more

Credit Suisse Pleads Guilty to DOJ Charge of Conspiracy to Aid Tax Evasion; FRB and NYDFS Take Related Actions

As widely reported in the financial press, Credit Suisse AG (“Credit Suisse”), a large Swiss bank that maintains a branch and other offices in the United States pleaded guilty to the felony of conspiracy to aid tax evasion by...more

Swiss Bank Pleads Guilty In Alleged Tax Evasion Conspiracy

On May 19, the DOJ announced that a Swiss bank pleaded guilty and entered into agreements with federal and state regulators to resolve a multi-year investigation into the bank’s alleged conspiracy to assist U.S. taxpayers in...more

Justice Department Files Appeal Brief in Beanie Babies Case

Two weeks ago, the Government filed its appeal brief in the case of United States v. Ty Warner, a case out of the Northern District of Illinois. It is rare for the United States to appeal a sentence, let alone a sentence in...more

DOJ Waging War Against Offshore Shell Companies

A Florida doctor was recently sentenced to multiple years in prison for income tax evasion. The taxpayer hid income and assets through the use of offshore bank accounts concealed by the use of offshore shell companies. This...more

Recent Sentences for Federal Tax Crimes in 2014 – Part 3

Today we conclude our review of recent sentences imposed in federal tax crime cases in 2014. In our two previous posts here and here, we reviewed sentences relating to Foreign Bank Account, Tax Evasion, Employment Tax, False...more

Focus on Tax Controversy and Litigation - Supreme Court Decides Woods v. Commissioner, Holds for IRS on Jurisdictional and...

In this issue: - US Supreme Court Imposes Valuation-Misstatement Penalty in TEFRA Proceeding - Southern District of New York holds Cooperation with Government Waives Attorney-Client Privilege - IRS Issues...more

Levin and McCain Urge DOJ to Seek Extradition of Fugitive Swiss Bankers

Bloomberg news reports that on March 18, 2014, U.S. Senators Carl Levin and John McCain wrote a letter urging the Justice Department to seek extradition of about 30 Swiss bankers and others who are charged with enabling...more

Senate Report Urges DOJ Action Regarding Offshore Tax Evasion, Enforcement Against Swiss Banks

On February 27, the Senate Permanent Subcommittee on Investigations (PSI) issued a report and held a hearing related to its multi-year investigation of offshore tax evasion and the DOJ’s efforts to pursue Swiss banks who...more

Who Is Next, Now That Swiss Banks Will Turn Over Account Data?

What do you do if your offshore account is at one of 14 Swiss banks currently under criminal investigation? What do you do if your offshore account is at one of the 106 Swiss banks that have entered into non-prosecution...more

6 Reasons US Taxpayers Should Report Assets Held in Swiss Banks Soon

Initial success of DOJ Swiss bank amnesty program creates greater urgency for US taxpayers. On December 31, 2013, the window to apply for the US Department of Justice’s (DOJ) amnesty program closed for certain Swiss...more

Release of Names With Interests in Offshore Entities: Ramifications

A database containing the names of more than 37,000 people with offshore entities and trusts in 10 tax haven jurisdictions was recently released online, providing a powerful investigative tool for regulators, journalists and...more

"Government Enforcement: Aggressive Efforts Continue Around the Globe"

Government enforcement efforts in 2013 produced major settlements of matters relating to the global financial crisis, high-profile insider trading convictions, near-record amounts of FCPA settlements, and new pledges of...more

Will the U.S. Dept . of Justice Find Your Offshore Account?

At a recent tax conference a senior official of the U.S. Department of Justice DoJ) is reported to have said: “We’ll be looking for you”....more

Raminfard Guilty Plea Highlights Complexity Of International Tax Compliance, Seriousness Of Violations, Importance Of IRS Offshore...

Los Angeles Businessman, David Raminfard, pleaded guilty on November 4th, 2013 in the Federal District Court in Los Angeles to conspiring to defraud the United States, the Justice Department and Internal Revenue...more

Crackdown on US Tax Evaders With Secret Offshore Accounts Leads to International Banking Reforms

Miriam Fisher, global Co-chair of the firm's Tax Controversy Practice, focuses her practice on federal tax controversy and litigation, including complex civil and criminal tax matters. Fisher spoke at the November 6, 2013...more

US - Swiss voluntary disclosure program: deadlines are looming - Swiss banks need not panic, but must act swiftly and thoughtfully

The recently announced voluntary bank disclosure program between Switzerland and the US offers worried Swiss banks the possibility of peace of mind from future prosecution. The question now confronting Swiss banks is whether...more

Justice Dept. Warning to Swiss Banks Means Trouble for U.S. Taxpayers

On November 5, 2013 the Department of Justice issued a letter of explanation to Swiss banks. A portion of the warning is restated: “Each eligible Swiss bank should carefully weigh the benefits of coming forward, and...more

More Swiss Banks Will Disclose/Cooperate with Offshore Tax Investigations

The U.S. Department of Justice (DOJ) offer of non-prosecution agreements to certain Swiss banks expires December 31, 2013. Swiss banks who know or suspect that they have violated U.S. law, but who are not currently the...more

US Allows Swiss Banks With Undisclosed Accounts To Wipe the Slate Clean

United States Department of Justice issues further information on amnesty program for Swiss banks, including details on the selection of an Independent Examiner. On November 5, 2013, United States Department of Justice...more

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