News & Analysis as of

Foreign Banks Banks Tax Evasion

Orrick, Herrington & Sutcliffe LLP

DOJ charges Swiss Bank with fraudulent activity; settles with bank to suspend charges

On December 4, the DOJ announced a deferred prosecution agreement and charges, in the Southern District of New York, a Swiss bank, requiring approximately $122.9 million in restitution for defrauding the U.S. government and...more

Blank Rome LLP

Three More Swiss Banks Resolve Their Tax Issues with the United States

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The Justice Department continues to announce resolutions with banks under its previously-announced Swiss Bank Program. On August 6, DOJ announced the names of three more Swiss banks receiving non-prosecution agreements:...more

Latham & Watkins LLP

Foreign Banks and Bankers Face New Risks From Swiss Bank Amnesty

Latham & Watkins LLP on

The first non-prosecution agreement signals expanded US tax enforcement opportunities at home and abroad. The US Department of Justice (DOJ) has announced the first non-prosecution agreement (NPA) with BSI, SA, (BSI)...more

Blank Rome LLP

Swiss Banks Pushing Back on Scope of Agreement with U.S. under Amnesty Program

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As reported yesterday by David Voreacos, Giles Broom, and Jeffrey Vogeli, 73 of the over 100 Swiss banks that enrolled in the Justice Department’s amnesty program for Swiss banks have written an 11-page letter requesting...more

Blank Rome LLP

DOJ Issues Further Guidance on Swiss Bank Program

Blank Rome LLP on

Recently the Justice Department’s Tax Division issued further “comments” regarding its “Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks.” In prior posts we have described this program designed to...more

Blank Rome LLP

FBAR Penalty to Face Excessive Fines Clause Test

Blank Rome LLP on

Last week, a federal jury in Miami found that Carl Zwerner had willfully failed to disclose his foreign bank account to the Treasury Department for calendar years 2004, 2005 and 2006. Zwerner now potentially owes the United...more

Holland & Knight LLP

As Swiss Banking Becomes More Transparent, Americans with Undeclared Swiss Accounts Are Warned

Holland & Knight LLP on

In a move that was likely celebrated by United States governmental officials, Swiss banking secrecy eroded even further on Thursday, March 6, 2014. This is the day that parliament voted to provide foreign tax authorities with...more

K&L Gates LLP

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

K&L Gates LLP on

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

Latham & Watkins LLP

US Allows Swiss Banks With Undisclosed Accounts To Wipe the Slate Clean

Latham & Watkins LLP on

United States Department of Justice issues further information on amnesty program for Swiss banks, including details on the selection of an Independent Examiner. On November 5, 2013, United States Department of Justice...more

BakerHostetler

U.S. DOJ Offers Landmark Non-Prosecution Deal for Swiss Banks

BakerHostetler on

On August 29, 2013, the U.S. Department of Justice announced a program, supported by the Swiss government, to encourage all Swiss banks to admit their role in U.S. tax evasion in exchange for non-prosecution agreements and...more

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