News & Analysis as of

Offshore Banks

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

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

The Accountant and the Paradise Papers

by Foodman CPAs & Advisors on

Under U.S. Tax Law, it is appropriate for an Accountant to advise a US Taxpayer regarding his tax efficiency if the Taxpayer wants to pay less tax and accumulate wealth. While tax avoidance is legal and encouraged by the...more

Manafort Indictment Alleges High-End International Money Laundering and Tax Fraud Involving Offshore Accounts

by Ballard Spahr LLP on

As the world now knows, an indictment against Paul Manafort, Jr., a former campaign chairperson for now-President Donald Trump, and Manafort’s associate, Richard Gates III, was unsealed yesterday. ...more

IRS Urges Foreign Financial Institutions To Renew Their FATCA Registrations

by Fox Rothschild LLP on

The Internal Revenue Service has issued a reminder to foreign financial institutions to renew their Foreign Financial Institution (FFI) agreement if required. These FFIs have until October 24, 2017 to complete their renewal....more

WSGR Fintech Update - September 2017

FinCEN Sanctions Offshore Virtual Currency Exchange - The Financial Crimes Enforcement Network (FinCEN) recently imposed civil money penalties of over $122 million against BTC-e (also known as Canton Business Corporation)...more

Justice Department’s Latest Offshore Bank Resolution Confirms Value Of Self-Disclosure And Voluntary Remediation By At-Risk...

by Fox Rothschild LLP on

The Justice Department revealed its latest offshore bank resolution by announcing that it had entered into a non-prosecution agreement with a Swiss asset management firm called Prime Partners. This means that Prime Partners...more

Mossack Fonseca Founders Arrested and Detained on Money Laundering Charges

by Ballard Spahr LLP on

The founders of Panamanian law firm Mossack Fonseca were arrested on Saturday, following their indictment on money-laundering charges allegedly tied to the ever-widening Petrobas corruption scandal in Brazil. Kenia...more

[Webinar] Business E-mail Compromise Scams - Practical Perspectives - January 12th, 10:30am EST

by Locke Lord LLP on

An increasing number of businesses are targeted by very sophisticated email scams designed to convince company employees responsible for executing financial transactions to wire funds to overseas accounts controlled by...more

Government Investigations: Use of the Financial Crimes Enforcement Network and Virtual Currency

by Moskowitz LLP on

Since 2009, the US Department of Justice has implemented an aggressive anti-tax evasion strategy that has changed by targeting tax havens that host financial intermediaries (i.e., banks) to the financial intermediaries...more

¿Ha recibido una Carta FATCA?

by Foodman CPAs & Advisors on

Muchos Expatriados Estadounidenses están recibiendo Cartas FATCA de los bancos del extranjero alrededor del mundo. Los bancos están enviando estas cartas en anticipación al Reporte FATCA del IRS para reportar la información...more

Have You Received a FATCA Letter?

by Foodman CPAs & Advisors on

Many U.S. expatriate taxpayers are receiving “FATCA” letters from offshore banks around the world. The banks are sending the letters in anticipation of their I.R.S. FATCA reports of U.S. taxpayer offshore financial...more

In Wake of Panama Papers Scandal Obama Calls for Stricter Bank Regulations, Tax Rules

In a news conference May 6, President Obama addressed recently announced rules and proposed regulations intended to help the U.S. fight tax evasion and other crimes connected to anonymous offshore companies and accounts. The...more

Your daily dose of financial news The Brief – 5.10.16

by Robins Kaplan LLP on

Big news out of the online lending space, as Lending Club’s chair and CEO—Renaud Laplanche—has resigned after an internal review “showed a violation of the company’s business practices” related to sales of $22 million in...more

Today’s Panama Papers Release May Require Immediate Action to Mitigate Risk of Criminal Prosecution

by Blank Rome LLP on

Action Item: Today at 2:00 p.m. (EDT), a massive database of information from the leaked “Panama Papers” files will be made public for the first time, identifying the real owners behind over 200,000 offshore companies set up...more

In Wake of Panama Papers Scandal Obama Calls for Stricter Bank Regulations, Tax Rules

In a recent news conference President Obama addressed rules and proposed regulations announced Thursday intended to help the U.S. fight tax evasion and other crimes connected to anonymous offshore companies and accounts. The...more

Justice Department Announces Historic Conclusion of Swiss Bank Program for Category 2 Institutions

by Blank Rome LLP on

The Justice Department achieved a historic milestone in its ground-breaking Swiss Bank Program with its announcement today of the final Category 2 bank resolution. The Justice Department executed its 80th and final agreement...more

Jerry Lucente Speaks

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

Jerry Lucente is a Small Business/Self Employed Territory Manager with the North Atlantic Region of IRS, which includes the six New England states, New York and New Jersey. He is responsible for four groups at IRS that...more

Focus on Tax Controversy and Litigation - Second Circuit Determines that Tax Memo Shared Between Taxpayers and Banks Is Protected...

by Shearman & Sterling LLP on

In addition to the discussion of the Second Circuit’s decision in Schaeffler, this month’s issue features articles regarding the “new” IRS Notices covering “Basket Options” and “Basket Contracts”, the Tax Court’s recent...more

Bridging the Week - November 2015 #3

by Katten Muchin Rosenman LLP on

Court Chastises SEC for Causing Unwarranted Collapse of Foreign Bank: A federal judge in New York severely criticized the Securities and Exchange Commission over its handling of a lawsuit against Caledonian Bank Ltd.,...more

IRS Seeks Identities of Americans with Undisclosed Belize Bank Accounts

by Foley & Lardner LLP on

Americans with secret accounts in Belize should take notice: the government is looking for you. The U.S. Department of Justice on September 15 filed a petition in federal court in Miami seeking permission to issue summonses...more

CFPB Reaches Out to Offshore Payday Lenders With Federal Complaint

Why it matters - The Consumer Financial Protection Bureau (CFPB) filed a new complaint against several commonly owned payday lenders, alleging that the defendants engaged in unfair, deceptive, and abusive acts and...more

INTERPOL and the tax man

by Estlund Law, P.A. on

A reader recently sent in the following questions: Can you tell me would the IRS issue a diffusion notice in a civil tax audit involving offshore banking? Would Interpol even accept a diffusion notice on a non criminal...more

Justice Department Announces That Three More Swiss Banks Reach Agreements Over Tax Evasion Claims

by Blank Rome LLP on

On July 30, 2015, the Justice Department’s Tax Division announced that three more Swiss banks — PKB Privatbank AG, Falcon Private Bank AG and Credito Privato Commerciale in liquidazione SA (CPC) – have cut deals with the U.S....more

Federal Court Holds Neither Janus, Nor Statute of Limitations Shields Alleged “Pump-And-Dump” Fraudsters From Civil Liability in...

by Carlton Fields on

In another example of the limits to which defendants may successfully rely on the Supreme Court’s decision in Janus Capital Group, Inc. v. First Derivative Traders, 131 S. Ct. 2296 (2011), earlier this summer, District Judge...more

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