News & Analysis as of

Swiss Banks Internal Revenue Service

Allen Barron, Inc.

What Happens If You Don't File an FBAR

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It is common for a US taxpayer to ask “what happens if you don’t file an FBAR or a Form 8938, Statement of Specified Foreign Assets with the IRS? Why do I have to worry about filing an FBAR in San Diego or anywhere in the US,...more

Allen Barron, Inc.

How Does the IRS Use AI to Identify Tax Cheats?

Allen Barron, Inc. on

Could Artificial Intelligence (AI) increase the likelihood of an IRS audit in your future? How does the IRS use AI to identify US taxpayers who attempt to hide assets, under-report income or otherwise cheat the IRS? In...more

Foodman CPAs & Advisors

The FATCA Loophole Will Bring More Enforcement Action

After a yearlong investigation, the US Senate Finance Committee probed into a FATCA Loophole and delivered an investigative report titled “The Shell Bank Loophole” that exposes a tax evasion scheme under a FATCA loophole...more

Fox Rothschild LLP

Are Bitcoins And Other Cryptocurrencies The Next Swiss Bank Accounts?

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We all know the French proverb; the more things change the more they stay the same. It has a place in the current controversy over the sudden collapse of Mt. Gox, Bitcoin’s leading dealer. Bitcoin is a virtual or...more

Foodman CPAs & Advisors

Did you know that the IRS has 59 Compliance Campaigns? Have your Audit Plan Ready!

Foodman CPAs & Advisors on

IRS Large Business and International (IRS LBI) currently has 59 Active Compliance Campaigns.  The purpose of the IRS compliance campaign strategy is to redefine large business compliance work and build a supportive...more

Foodman CPAs & Advisors

IRS can start asking questions about Campaign Issues. Have your Audit Plan Ready!

Foodman CPAs & Advisors on

On January 31, 2017, the IRS Large Business and International Division (LBI) announced a compliance campaign strategy to redefine large business compliance work and build a supportive infrastructure inside the LBI. ...more

Ballard Spahr LLP

2016 Year End Review: Virtual Currency: DOJ and IRS Broadly Seek Virtual Currency Account User Information

Ballard Spahr LLP on

Under Internal Revenue Code section 7609(f), the IRS may issue a “John Doe” administrative summons to discover the identities of unknown taxpayers. A “John Doe” summons can be a powerful enforcement tool because it allows the...more

Holland & Knight LLP

The High Cost of Being Noncompliant with the Internal Revenue Code

Holland & Knight LLP on

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

K&L Gates LLP

Singapore’s Banking Secrets - Not So Secret Anymore

K&L Gates LLP on

Since 2008, the U.S. Government has largely focused its enforcement actions against Swiss banks that may have assisted U.S. taxpayers in evading federal taxes. In August 2013, the Department of Justice (“DOJ”) introduced the...more

Pillsbury Winthrop Shaw Pittman LLP

Hong Kong & Singapore: Awaiting a New DOJ Tax Program for Asian Banks?

As the Department of Justice is wrapping up its prosecution of over a dozen Swiss banks, federal prosecutors and IRS special agents are analyzing a treasure trove of previously undeclared taxpayer account information that...more

The Volkov Law Group

The Legacy of Michigan Senator Levin and Offshore Taxation Issues

The Volkov Law Group on

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

Blank Rome LLP

Offshore Tax Enforcement Update: DOJ Announces Criminal Charges Against Bank Julius Baer

Blank Rome LLP on

The U.S. government has filed criminal charges against another Swiss Bank — Bank Julius Baer — and simultaneously secured guilty pleas from two Julius Baer bankers who had been fugitives for the past five years. Pursuant to...more

BakerHostetler

Global Tax Enforcement in 2016: What You Need to Know

BakerHostetler on

The investigation and prosecution of tax evasion has, in the past decade, grown from a specialized subcategory of law enforcement into a first-tier policy concern for the international community. Financial institutions,...more

Blank Rome LLP

Internal Revenue Service Issues Stern Warning To Non-Compliant Taxpayers With Offshore Holdings

Blank Rome LLP on

Just one day after the October 15 deadline for filing personal income tax returns on extension, the Internal Revenue Service issued a strongly-worded warning to non-compliant taxpayers: take action now to fix your problem, or...more

Blank Rome LLP

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

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

Blank Rome LLP

Two More Swiss Banks Reach Resolutions with U.S. Government

Blank Rome LLP on

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

Blank Rome LLP

Two More Banks Reach Resolutions Under Justice Department’s Swiss Bank Program

Blank Rome LLP on

On June 3, 2015, the Justice Department announced that two more Swiss banks, Rothschild Bank AG and Banca Credinvest SA, reached resolutions under the DOJ Swiss Bank Program. Yesterday’s announcement brings the total Swiss...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

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