One Note Samba
The Panama Papers - What the Fallout Means for U.S. Companies and Professionals
The Panama Papers & The Tempo of International Corruption Cases
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
Court rules that a "John Doe" summons to obtain confidential client records from a law firm isn’t barred by attorney-client privilege. On May 15, 2019, a district court in the Western District of Texas held that the...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
Given the information publicly revealed by “Panama Papers”, and recent IRS reminders to out-of-compliance US Taxpayers to come into full compliance with their federal tax obligations, it is critical that Bankers and Financial...more
The IRS currently offers the following five programs for noncompliant taxpayers: (i) the Offshore Voluntary Disclosure Program (OVDP), (ii) Streamlined Domestic Offshore Procedures, (iii) Streamlined Foreign Offshore...more
IRS has asked involved U.S. taxpayers to come forward before IRS reads and dissects the “Panama Papers”. IRS will “plan how to use the huge trove of leaked documents to catch criminals — and urged Americans to come clean now...more
In the wake of the "Panama Papers" – the unprecedented leak of 11.5 million files from a Panamanian law firm that revealed thousands of names and addresses linked to offshore companies – the White House has announced several...more
On May 10, 2016, the Treasury Department issued proposed regulations that, if approved, will require business entities formed in the United States that are owned by a single foreign person to obtain an employer identification...more
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
Generally, a disregarded entity is not subject to U.S. tax or information reporting, so the IRS is limited to gleaning information from tax filings by an entity’s owner. But foreign owners of disregarded entities often do not...more
When Senator Levin, the Democrat from Michigan, announced his retirement from the Senate in 2014, you could hear a collective sigh of relief from the corporate business community. Senator Levin had dedicated himself to...more
As part of the U.S. Treasury Department's ongoing efforts to prevent bad actors from using U.S. companies to conceal money laundering, tax evasion, and other illicit financial activities, the Financial Crimes Enforcement...more
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 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
On April 3, 2016, the International Consortium of Investigative Journalists (“ICIJ”) published more than 11.5 million documents connected to Mossack Fonseca, a Panama law firm that helped establish offshore financial...more