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
Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more
The Department of Justice (DOJ), IRS Criminal Investigations (CI) and international tax authorities continue to prosecute tax abuses related to digital asset transactions. In imposing a multiyear prison sentence in a recent...more
On 14 February, the EU Council added four jurisdictions (the British Virgin Islands, Costa Rica, Marshall Islands and Russia) to the list of non-cooperative jurisdictions (Annex I) (the “EU Blacklist”)....more
Key Takeaways - ..The Joint Chiefs of Global Tax Enforcement (J5) issued its first intelligence bulletin providing guidance to banks, law enforcement partners and private investigators regarding indicators of potential...more
On December 22, 2021, the European Commission published proposals for a Directive which targets the perceived misuse of “shell” entities for tax purposes. The draft of the Directive proposes a common minimum substance test...more
Taxpayers have long utilized trust arrangements for the transfer of wealth to beneficiaries or for the protection of assets from creditors. Generally, there is nothing nefarious about these types of arrangements. Rather,...more
United States citizens and residents[i] are subject to federal income tax on their worldwide income. For example, even if a United States citizen permanently relocates to a foreign country, he or she will generally continue...more
On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account...more
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
Qu’est-ce que le Foreign Account Tax Compliance Act (« FATCA ») ? Depuis plusieurs années, l’IRS mène une campagne agressive contre la fraude fiscale internationale et la nondéclaration de comptes bancaires et autres...more
Despite the market disruption caused by the COVID-19 pandemic, sovereign wealth funds continued to make significant capital commitments to private funds during 2020, on a global basis. As the world emerges from the pandemic,...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
The European Council has announced its decision to remove the Cayman Islands from the EU list of non-cooperative jurisdictions for tax purposes. In February we reported on Cayman’s inclusion on the list and our expectation...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 17 – 21, 2020. February 18, 2020: The IRS issued a revenue ruling providing various...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
On 18 February 2020, the ECOFIN committee of finance ministers of the EU resolved to add the Cayman Islands to the EU blacklist of non-cooperative jurisdictions for tax purposes. Their reasoning was short...more
The Cayman Islands Receive “Top Honors.” But, Global Financial Transparency is Reportedly Improving in General - The United States has overtaken Switzerland as a financial secrecy haven, according to the latest rankings –...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
En términos generales, los cambios impositivos propuestos más grandes de Colombia tendrían un impacto en el Impuesto sobre las ventas (IVA), la creación de un impuesto unificado denominado SIMPLE, la emisión del impuesto a la...more
The IRS-Criminal Investigation Unit (IRS-CI) is the Criminal Law Enforcement Arm of the IRS. Its conviction rate of over 90% is one of the highest in federal law enforcement. Those convicted pay taxes, penalties and...more
Detectar, disuadir y responder al incumplimiento internacional son desafíos clave que enfrentan las autoridades tributarias de todo el mundo. El incumplimiento fiscal internacional es un problema significativo reconocido por...more
The governments of Argentina and the United States signed on December 23rd, 2016, a new tax information exchange agreement (“TIEA”). Jack Lew, U.S. Treasury Secretary, stated that the TIEA will allow for important...more
Talk about a regulation with teeth. Within days of the Treasury Department announcing new rules meant to discourage corporate tax inversion deals, Pfizer and Allergan announced they were scrapping their planned $152 billion...more
On Sept. 9, 2014, in U.S v. Robert Bandfield et al., federal prosecutors in the Eastern District of New York announced the indictment of a U.S. citizen and others, including offshore corporate service providers (CSPs) and...more