News & Analysis as of

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

U.S. Department of Justice Awaits Swiss Banks’ Voluntary Disclosure of Banking Activities

The U.S. Department of Justice (“DOJ”) established a Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (the “Program”) on August 29, 2013. The Program is intended to facilitate a resolution with the...more

US DOJ and Swiss government announce new voluntary disclosure program for Swiss banks

In recent years, the US Department of Justice has been aggressively investigating the use of bank accounts outside the US to evade tax. While emphasizing that its enforcement activities are and must remain global, the DOJ has...more

The DOJ Ratchets Up Its Crackdown On Swiss Bank Accounts

In my last post, I discussed the possibility that Bitcoins and other virtual currencies could replace Swiss bank accounts as the tax havens of the future. Recent developments in the government’s war on offshore accounts...more

U.S. Department of Justice & Swiss Federal Department of Finance Enter into Historic Agreement Regarding Tax Evasion...

Continuing its mission to eradicate offshore tax evasion, on August 29, 2013, the United States Department of Justice Tax Division (the “DOJ”) and the Swiss Federal Department of Finance issued a Joint Statement regarding the...more

Tax Law Blog: Tax Evasion Charges for Ty Beanie Babies Creator

I have to think most people at least know what a "Beanie Baby" is, and some of you may still have them in your homes (someday they will be collector items, right?). This morning, Ty Warner, the creator of Beanie Babies, was...more

US, Switzerland Announce Tax Evasion Program

On August 29, the DOJ announced a program to encourage Swiss banks to cooperate in its ongoing efforts to prosecute offshore tax evasion. The program—which, according to a joint statement with the Swiss Federal Department of...more

U.S. DOJ Offers Landmark Non-Prosecution Deal for Swiss Banks

On August 29, 2013, the U.S. Department of Justice announced a program, supported by the Swiss government, to encourage all Swiss banks to admit their role in U.S. tax evasion in exchange for non-prosecution agreements and...more

The Offshore Voluntary Disclosure Program: A Brief History And Overview Of The Complexities Involved In Disclosing Foreign Assets

The IRS and the Justice Department have increased their efforts regarding criminal investigation of international tax evasion. ...more

Indian American Neurosurgeon Sentenced to Probation for Unreported Offshore Bank Accounts

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

Offshore Banks, Required Records and Secret Funds Transfers: a Receipe for Disaster

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

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