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Finance & Banking International Trade Tax

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IRS Signals Intent to Aggressively Pursue Undisclosed Offshore Accounts

by Varnum LLP on

At the recent National Institute on Criminal Tax Fraud and Tax Controversy, senior IRS and Department of Justice (Tax) officials sounded the proverbial warning alarm to taxpayers with undisclosed or offshore financial...more

EU “Black Lists” Bahrain and UAE as Non - Cooperative Jurisdiction for Tax Purposes

by King & Spalding on

On 5 December 2017, the Economic and Financial Affairs Council (ECOFIN) determined a list of 17 non-cooperative jurisdictions, which included Bahrain and the United Arab Emirates (UAE). This list was established based on...more

U.S. v. Coinbase: Virtual Currency Holders Not Outside the IRS’s Reach

by Dechert LLP on

The U.S. District Court for the Northern District of California, on November 28, 2017, ordered the international digital currency broker, Coinbase, Inc., to produce to the Internal Revenue Service (IRS) the records of...more

France Announces Its First Deferred Prosecution Agreement

In a move that could signal a new phase of government enforcement in France, on November 27, 2017, French authorities published a Convention judiciaire d’intérêt public (CJIP) with HSBC Private Bank Suisse SA (HSBC PB), the...more

DOJ Announces Major New Shift in Criminal Sentencing in Offshore Tax Matters

At the 34th Annual National Institute on Criminal Tax Fraud in Las Vegas yesterday afternoon, Mark Daly, DOJ Tax Division Senior Litigation Counsel announced a major new shift in how the Department of Justice plans to argue...more

Income, from Whatever Exchange, Mine, or Fork Derived: The Basics of U.S. Cryptocurrency Taxation

by Proskauer - Tax Talks on

In this first of (we hope) many posts on the interesting and myriad tax issues arising in the world of cryptocurrency and blockchain technology, we focus on the very basic U.S. federal income tax consequences of...more

Recent Developments in Transfer Pricing and the Taxation of Multinational Companies in Australia

by Jones Day on

As part of a wide-ranging crackdown on multinational tax avoidance, the Australian Federal Government and the Australian Tax Office have introduced significant reforms to the country’s transfer pricing regulations. The...more

Paradise Papers: The Latest Offshore Leak

by Jones Day on

Hackers leaked approximately 13.4 million confidential client documents from Appleby, Estera, and Asiaciti Trust to the International Consortium of Investigative Journalists....more

Estate Planning Under the Tax Cuts and Jobs Act

If enacted, the Tax Cuts and Jobs Act could open up significant estate planning opportunities. The House bill doubles the exemptions from estate, gift and generation-skipping transfer taxes, creating new opportunities for...more

Asset Management Regulatory Roundup - November 2017 - Issue 11

by Dechert LLP on

A compact summary of the most recent regulatory and tax developments relevant to the UK asset management industry. This issue includes details on ESMA’s updated Q&As on the key information document requirements for PRIIPs;...more

How Proposed Tax Reform Will Impact Private Equity

by Foley & Lardner LLP on

Both the House of Representatives and the Senate have proposed their own versions of tax reform (the “House Proposal” and “Senate Proposal”, respectively, and together, the “Proposals”) which will drastically change the...more

What would happen to the value of cryptocurrencies if Exchanges had to Issue a Form 1099 on an annual basis?

by Sanford Millar on

The IRS issued a John DOE Summons for records of U.S. account holders of Coinbase, Inc. (“Coinbase”) a cryptocurrency exchange based in San Francisco, California. Coinbase objected to production of the records and a Summons...more

Orrick's Financial Industry Week In Review

CFTC’s Division of Market Oversight Extends Time-Limited No-Action Relief for SEFs from Certain Block Trade Requirements - On November 14, 2017, the U.S. Commodity Futures Trading Commission's Division ("CFTC") of Market...more

Paradise Papers, Panama Papers…. The Message is Clear: Report Offshore Accounts!

by Foodman CPAs & Advisors on

First, the Panama Papers, and now… the Paradise Papers. The Paradise Papers contain the names of approximately 31,000 US citizens, including entities, or persons with US addresses....more

What If You Are Ineligible For The Offshore Voluntary Disclosure Program? Attorney Proffers versus Quiet Disclosures

by Sanford Millar on

Since the beginning of the current Offshore Voluntary Disclosure Programs (OVDP) in 2009 tens of thousands of U.S. taxpayers have come forward to report previously undisclosed foreign financial accounts. The addition of the...more

Notes on the Financial Surveillance Special Voluntary Disclosure Programme process

by Hogan Lovells on

The Financial Surveillance Special Voluntary Disclosure Programme (the FinSurv SVDP) was announced by the Minister of Finance in the February 2016 Budget Speech....more

House of Representatives Passes the Tax Cuts and Jobs Act (H.R. 1); Senate Finance Committee Approves Modified Version; Comparison...

by Proskauer - Tax Talks on

Yesterday afternoon, the House of Representatives passed the Tax Cuts and Jobs Act (H.R. 1) (the “House bill”). The House bill is identical to the draft bill approved by the House Ways and Means Committee on November 10. Late...more

Executive Regulation on Value Added Tax in the UAE

by Bracewell LLP on

The United Arab Emirates (“UAE”) Federal Tax Authority has recently published the draft Executive Regulations of Federal Decree Law No. 8 of 2017 on Value Added Tax (the “VAT Law”) which introduces a 5% VAT on the import and...more

Will Your Offshore Bank or Cryptocurrency Exchange Turn You In to the IRS?

by Sanford Millar on

Well the results of the Foreign Account tax Compliance Act (“FATCA”) are coming in and the IRS will be stepping up audit of “holder” of unreported account. The exam targets will be U.S. taxpayers who own or control foreign...more

On Eve Of “Paradise Papers” Release, At-Risk Individuals Should Consider Immediate Action To Mitigate Potential For Criminal...

by Fox Rothschild LLP on

Tomorrow morning (November 17) the International Consortium of Investigative Journalists (ICIJ) is set to release publicly the first set of comprehensive data from the recent “Paradise Papers” leak. The initial data will...more

The Senate Finance Committee’s proposal for tax reform, and how it compares with the bill passed by the House Committee on Ways &...

by Proskauer - Tax Talks on

UPDATE: The Senate Finance Committee last night released a revised version of the Chairman’s Mark of the Tax Cuts and Jobs Act. We are reviewing these changes and will release an update soon... On Thursday, November 9, the...more

International Tax Issues Are A Major Focus of Newest Launch of IRS Compliance Campaigns in 2017

by M. Robinson & Company, P.C. on

Earlier this year, the IRS Large Business and International division (LB&I) rolled out 13 compliance campaigns to target both individual taxpayers and corporations for examinations on certain tax compliance issues. On...more

Tax Reform and Nonprofits: The Devil’s in the Details

by Morgan Lewis on

The Tax Cuts and Jobs Act, currently under consideration in the US House of Representatives and Senate, proposes fundamental changes to the US tax law affecting all sectors of the economy, including nonprofit organizations....more

The failure to prevent tax evasion

by WilmerHale on

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

Proposed Changes for Estate, Gift and Generation-Skipping Taxes Introduced in Tax Cuts and Jobs Act - Update

by McDermott Will & Emery on

In Depth - UPDATE: On November 9, 2017, the Senate Finance Committee released “policy highlights” of its forthcoming version of the Tax Cuts & Jobs Act. Like the House bill, the Senate version doubles the “death tax”...more

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