Voluntary Disclosure

News & Analysis as of

MoFo New York Tax Insights - Volume 5, Issue 7 - July 2014

In This Issue: - Department of Finance Announces Updated Commercial Rent Tax Audit Policy on Billboards - ALJ Finds No Hearing Right To Challenge Notice and Demand, and Corporate “President” Is Personally...more

The Self-Referral Disclosure Protocol: Settlement and Enforcement Trends (Presentation)

The Self-referral Disclosure Protocol (SRDP) permits health care providers to voluntarily disclose violations of the federal physician self-referral law, also called the Stark law. Emily Wein has presented a webinar...more

The Countdown is On for the Delaware Voluntary Disclosure Program

The deadline is quickly approaching for participation in the Delaware Secretary of State’s Unclaimed Property Voluntary Disclosure Program. Businesses have until June 30, 2014, to enroll in the program, and another year to...more

IRS Commissioner Hints That OVDP Modifications Are in the Works

Since 2009, the Internal Revenue Service has offered three different amnesty programs for taxpayers with undeclared foreign bank accounts. These programs, the current version of which is entitled the Offshore Voluntary...more

The SEC’s (New) Admissions Policy: Questions and Consequences

Nearly a year has passed since the SEC announced that it would require admissions of wrongdoing as a condition of settling SEC charges in certain cases. Perhaps it can no longer be called a “new” policy. But lawyers are still...more

The Deadline for Submitting Comments Regarding the Self-Referral Disclosure Protocol Is Fast Approaching

On May 2, 2014, the Centers for Medicare and Medicaid Services (“CMS”) published a request for comments relating to the Self-Referral Disclosure Protocol (“SRDP”). The SRDP is a voluntary self-disclosure instrument that...more

Comments Due for New Expedited Review Process for CMS's Voluntary Self-Referral Disclosure Protocol (SRDP)

The creation of the SRDP through the Affordable Care Act as a mechanism to resolve potential Stark violations was welcomed by the industry. However, since enactment of the regulations implementing the SRDP in 2010, the volume...more

IRS Issues Retroactive Relief Requirement for Delinquent Retirement Plan Form 5500

Until now, those who used the Department of Labor’s Delinquent Filer Voluntary Compliance Program (DFVCP) to obtain relief from penalties for failing to timely file Form 5500 automatically qualified for relief from the...more

The Clock Is Ticking: Consider the Delaware Voluntary Disclosure Program Before It Sunsets

The deadline is quickly approaching for participation in the Delaware Secretary of State's Unclaimed Property Voluntary Disclosure Program. Businesses have until June 30, 2014, to enroll in the program, and another year to...more

Roadmap To IRS' Offshore Voluntary Disclosure

In January of 2012 the Internal Revenue Service enacted the Offshore Voluntary Disclosure Program, or OVDP for short. This is actually the third recent version of the offshore voluntary disclosures. The voluntary disclosure...more

Tech Company Shares Tech, Makes Self-Disclosure, Pays Penalty

On February 19, 2014, the U.S. Commerce Department announced that it had reached an agreement with Santa Clara-based Intevac, Inc. to settle allegations that Intevac violated U.S. export regulations governing exports of...more

Battuta D'arresto Per La Voluntary Disclosure

Come annunciato, l'articolo 1 del decreto legge 28 gennaio 2014, n. 4 (pubblicato in G.U. n. 23 del 29 gennaio 2014 – di seguito "Decreto") in materia di "Voluntary Disclosure" o "Collaborazione Volontaria" per il rientro dei...more

OFCCP’s New Voluntary Self-Identification Requirements

Federal contractors must invite job applicants and employees to voluntarily self-identify as individuals with disabilities using a form that was recently released by the Office of Federal Contract Compliance Programs (OFCCP)....more

Merger And Acquisition Due Diligence And Voluntary Disclosures

The Justice Department and the SEC continue the drumbeat encouraging companies to voluntarily disclose potential FCPA violations. Of course, the reason for their position is obvious – they want to know about every violation,...more

OFCCP Self-ID Form: 5 Things Contractors Should Know

As we previously reported, the Office of Federal Contract Compliance Programs (OFCCP) in August adopted new rules intended to improve job opportunities for veterans and persons with disabilities....more

Accountant And Attorney Liability Newsbrief - Winter 2014

In This Issue: - Offshore Disclosure Programs—A Trap for CPAs? - Superior Court Imposes Sanctions for Withholding Documents in Discovery - Expert Witness Faces Personal Liability for Professional Malpractice - U.S....more

OFCCP Issues Final Disability Self-Identification Form

The Office of Federal Contract Compliance Programs (OFCCP) has released the revised Voluntary Self-Identification Form CC-305. All federal contractors will be required to use this form in inviting applicants and employees to...more

OFCCP Disability Self-ID Form Approved

New disability regulations issued by the Office of Federal Contract Compliance Programs (OFCCP) mandate that covered federal contractors and subcontractors invite applicants and employees to self-identify their disability...more

The OFCCP Disability Self-Identification Form Has Been Finalized

On January 22, 2014, the Office of Management and Budget (OMB) approved the OFCCP's disability status form, which will be used by federal contractors. Revised regulations under the Rehabilitation Act will require federal...more

OMB Approves Section 503 Voluntary Self-Identification Form

On January 22, 2014, after several months of review, the Office of Management and Budget (“OMB”) finally approved the voluntary self-identification form required by the Section 503 Final Rule that becomes effective on March...more

January 2014 Recent Trends and Patterns in Foreign Corrupt Practices Act (FCPA) - Enforcement report only

In this issue: - Enforcement Actions and Strategies - Perennial Statutory Issues - Unusual Developments - Compliance Guidance - Private Litigation - Enforcement in the United...more

Is Time Running Out for the Offshore Voluntary Disclosure Program?

The deadline imposed by the Department of Justice (DOJ) for approximately 300 Swiss banks to come forward and request non-prosecution agreements expires December 16, 2013. In order to be eligible for a non-prosecution...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

U.S. Senators Debate Toughening Cartel Penalties

On November 14, 2013, members of the Senate Committee on the Judiciary, Subcommittee on Antitrust, Competition Policy and Consumer Rights heard arguments regarding the effectiveness of current cartel prosecution and...more

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