News & Analysis as of

Offshore Accounts? IRS is Watching

If you have unreported income from offshore accounts, now may be the best time to come forward and report those earnings; otherwise, you may be susceptible to criminal prosecution. The IRS initially began this...more

Senator Grassley Urges IRS to Strengthen Whistleblower Program

Both in our practice and on our blog, we typically focus on the SEC Whistleblower Program, which seeks actionable intelligence about possible violations of the federal securities laws. But, the SEC Whistleblower Program is...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

FATCA: Initial Registration Deadline Extended

On April 2, 2014, the IRS announced that foreign entities that must be FATCA-compliant by July 1, 2014 now have until June 3, 2014 to register with the IRS (as opposed to the previous April 25, 2014 registration deadline)....more

My, What Long Arms You Have, Uncle

Here’s a visual: Uncle Sam extending his arms around the world, reaching out for his citizens, wherever they may be. He may resemble a candy-striped Gumby, with disproportionately long rubbery arms spanning the globe. The...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

Update: U.S. International Tax Enforcement Efforts

On February 25, 2014 the U.S. Senate Permanent Subcommittee on Investigations, issued its report on its investigation into offshore tax evasion and the participation of Swiss Banks. Specific recommendations were made, among...more

First Lady Of Tax Fraud

The IRS just issued its Criminal Investigation Annual Report. Budget constraints caused the staffing of Special Agents to drop to the lowest numbers in recent history, but 2013 included a 12.5 percent increase in...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

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

The Cloak of Invisibility for Foreign Accounts Is Rapidly Unraveling: IRS and Foreign Banks Are Clamping Down on U.S. Tax Evasion

A global push for enhanced financial transparency means that United States owners of foreign accounts and assets will not be able to remain invisible forever. New rules and enhanced enforcement of existing rules will soon...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

"Financial Institutions Wrestle With FATCA Implementation"

Over the past year, financial institutions have wrestled with the challenges presented by the U.S. Foreign Tax Compliance Act (FATCA). Originally scheduled to take effect in 2013, the U.S. Treasury Department and IRS have...more

FBAR E-Filing and Signature Authority: What You Need to Know

Much has been written about the IRS's dogged pursuit of taxpayers with unreported foreign accounts. These accounts are reported on the Report of Foreign Bank and Financial Accounts (FBAR) when a taxpayer has a financial...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

The IRS and Gun Control

Earlier this month, the First Circuit Court of Appeals held in a case of first impression that evidence seized by IRS special agents from the taxpayer's home was admissible even though IRS Special Agents were armed when they...more

Federal Court Rejects Efforts to Diminish Measures Aimed at Reducing Offshore Tax Avoidance

As of January 1, 2013, United States banks were required to report to the IRS interest earned by nonresident aliens who are residents of certain foreign countries. The reporting requirement previously existed for accounts...more

Tax Law Blog: The Impact of FATCA

The U.S. government loses an estimated $150 billion in revenue each year from offshore tax shelters. The Foreign Account Tax Compliance Act (FATCA), which became law in March 2010, is designed to prevent tax evasion by U.S....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

Cayman Islands and U.S. Sign FATCA IGA

On November 29, 2013, the Cayman Islands and the U.S. Signed a FATCA IGA. The Cayman Islands IGA is a Model 1B agreement, meaning that FFIs in the Cayman Islands will be required to report tax information about U.S. account...more

International Tax News - November 2013

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...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

Criminal FBAR Prosecutions Underscore Importance of IRS Offshore Voluntary Disclosure Program

According to statistics compiled by Jack A. Townsend, author of the Federal Tax Crimes Blog, nearly 130 individuals have been charged with maintaining and failing to report offshore bank accounts, or enabling those who do. ...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

48 Results
|
View per page
Page: of 2