There has been a legal shakeup this summer in the world of “FBARs”—Reports of Foreign Bank and Financial Accounts. New developments have been popping up nearly every week, whether from a court decision, as a result of a...more
In most cases, IRS exam initiates FBAR assessments. And, after an IRS examiner determines that an FBAR penalty is appropriate, taxpayers are generally afforded pre- or post-assessment appeals rights with the IRS Independent...more
On July 29, 2021, the United States Attorney for the Southern District of New York, the Assistant Attorney General for the Department of Justice Tax Division, and the IRS Commissioner all announced that a federal court in New...more
How much of the Paycheck Protection Program (“PPP”) will end up in the hands of bad actors? With several hundreds of billions of dollars in the PPP bucket, fraud, misuse, and misdirection of funds is already being identified...more
On March 13, 2018, the Internal Revenue Service ("IRS") announced that the Offshore Voluntary Disclosure Program ("OVDP") will end on September 28, 2018. The program has allowed taxpayers to avoid criminal prosecution by...more
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
Today the Justice Department announced that Société Générale Private Banking (Suisse) SA (SGPB-Suisse) and Berner Kantonalbank AG (BEKB), have reached resolutions under the department’s Swiss Bank Program. With today’s...more
In This Issue: - Eleventh Circuit Holds that Production of Foreign Bank Account Records May be Compelled in Criminal Investigation Under Required Records Exception to Fifth Amendment Privilege - Supreme Court...more