Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
UK corporate offence of failure to prevent tax evasion
The Panama Papers - What the Fallout Means for U.S. Companies and Professionals
Foreign Bank Account Reporting and Employment Tax Enforcement: Ronn Owens interviews Steve Moskowitz
The Panama Papers & The Tempo of International Corruption Cases
Lauryn Hill's Tax Evasion a 'Battle for Survival': Lawyer
The UK government is pressing ahead with its proposal to require large businesses to notify their “uncertain tax positions” to HMRC. ...more
Tax avoidance is the process of manipulating tax rules to reduce the amount of tax payable and obtaining a financial advantage that was never the intention of the legislation. A typical example of tax avoidance involves the...more
With effect from December 1, 2020, Her Majesty's Revenue and Customs ("HMRC") ranks ahead of floating charge holders and unsecured creditors with respect to recovering certain pre-insolvency taxes from an insolvent business...more
During the course of 2020, the U.K. government has pushed ahead with introducing new measures that are likely to be of material relevance to financial restructurings and corporate reorganizations. There have also been other...more
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
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
Draft legislation included in the Finance Bill 2019-2020 will potentially make directors and certain other individuals closely connected to a company jointly and severally liable for a company’s tax liabilities that arise...more
A notable feature of the UK tax landscape is the ever-increasing powers available to the UK tax authority, HM Revenue & Customs (“HMRC”), to challenge all forms of tax non-compliance. However, questions have arisen in recent...more
HMRC has released a consultation document in respect of its draft regulations implementing the EU mandatory tax disclosure rules that will apply from 1 July 2020 to intermediaries and relevant taxpayers in relation to...more
On 9 May 2019, the House of Commons Library published a lengthy report, “Tax avoidance and tax evasion” (the “Report”). The Report summarises some of the government’s key measures to tackle tax avoidance and tax evasion,...more
HM Revenue & Customs has provided a timely reminder of the need for organisations with a connection to the United Kingdom to review their prevention procedures regarding the failure to prevent the facilitation of tax evasion...more
HMRC has announced today the introduction of a new Profits Diversion Compliance Facility, which is aimed at tackling the avoidance of tax by multinationals by diverting profits outside the UK without proper economic...more
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
UK asset managers, non-UK asset managers carrying on business in the UK and the funds they manage are within the scope of the new corporate criminal offences of failing to prevent the facilitation of tax evasion. As the new...more
UK Tax News and Developments - Finance (No 2) Bill 2017 - The second Finance Bill of 2017, known as Finance (No 2) Bill 2017, has now been published. As expected, this contains most of the provisions which were dropped from...more
UK Tax News and Developments - Conservative legislative agenda set out in Queen's Speech - Following the UK general election on 8 June 2017, at which the Conservative party won the largest number of seats but lost its...more
The Criminal Finance Act 2017 received Royal Assent on April 27, 2017, making its way onto the statute book before the halting of Parliamentary business ahead of this year’s general election. As well as giving enforcement...more
The Criminal Finances Act 2017, which received Royal Assent last week, contains the largest expansion of UK corporate criminal liability since the Bribery Act 2010 and one of the most significant overhauls of money laundering...more
What does real estate investment have to do with the problem of tax evasion made possible by cash-in-hand payments in the building industry? Very little, one might suspect, but that has not prevented real estate investors...more
The U.K. government is set to introduce a new corporate criminal offence, based on the strict liability of the entity in question. It almost certainly will come into force in 2017, once the Criminal Finances Bill (Bill) is...more
The U.K. government expands its crackdown on tax evaders and the persons who assist them, by targeting businesses who fail to prevent tax evasion....more
A proposed new UK law contains the largest expansion of UK corporate criminal liability since the Bribery Act 2010 and one of the most significant overhauls of money laundering and proceeds of crime legislation in the last...more
With the publication of the draft Criminal Finances Bill 2016-2017 on 13 October 2016, businesses have been put on notice of what stands to be the largest expansion of UK corporate criminal liability since the Bribery Act...more
Many people will be familiar with the information gathering and reporting requirements the OECD’s Common Reporting Standard (“CRS”) places on financial institutions. The first exchanges of information between tax authorities...more
The UK’s tax authority, Her Majesty’s Revenue & Customs (HMRC), has just closed its consultation on a new corporate criminal offence: failure to take reasonable steps to prevent tax evasion....more