Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
UK corporate offence of failure to prevent tax evasion
The Panama Papers - What the Fallout Means for U.S. Companies and Professionals
Foreign Bank Account Reporting and Employment Tax Enforcement: Ronn Owens interviews Steve Moskowitz
The Panama Papers & The Tempo of International Corruption Cases
Lauryn Hill's Tax Evasion a 'Battle for Survival': Lawyer
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
The Department of Justice is starting to launch its FCPA enforcement profile after a brief lull in DOJ’s transition to a new administration. This enforcement lull occurred in the transition to the prior administration in...more
Crypto Initiatives Launched by Foreign Banks, Exchanges, Apps, Gaming Firms - According to a press release this week, the “Bank of Thailand (BOT) … has successfully launched the world’s first blockchain-based platform for...more
Jobs Report Friday again. Here’s what we’re watching, including the possibility of scary low numbers thanks to the only-recently-resolved GM strike....more
In the internal battle between keeping China off balance and keeping Wall Street happy, the White House has decided once again to focus on the latter, walking back the latest tariff escalation by postponing promised...more
In a move that could signal a new phase of government enforcement in France, on November 27, 2017, French authorities published a Convention judiciaire d’intérêt public (CJIP) with HSBC Private Bank Suisse SA (HSBC PB), the...more
2016 was a busy year for developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues. In part one of our year-in-review, we discuss six key...more
In the short term, demonetization has completely dampened the Indian economy. On November 8, 2016, Indian Prime Minister Narendra Modi declared that the two highest denomination currency notes, INR 500 notes (USD 7.3)...more
Federal regulators unveiled a proposal yesterday that would push the country’s biggest banks and other “critical financial companies” to shore up cybersecurity protocols, to prevent hacks, and to have a recovery plan at the...more
Continual rejections worked for Hershey in fending off Mondelez’s takeover bid. The Deal Professor thinks that Tronc faces considerable risks in following the same strategy with Gannett’s repeated overtures....more
Since the September 11, 2001, terrorist attacks, U.S. law enforcement and financial regulatory agencies have focused on disrupting the use of the financial system by terrorist groups, criminal organizations and tax evaders to...more
On May 5, 2016, the U.S. Department of the Treasury announced several actions to strengthen financial transparency. Treasury announced a Customer Due Diligence (CDD) Final Rule, proposed Beneficial Ownership legislation and...more
Two more Swiss banks have reached resolutions with the Justice Department under its Swiss Bank Program. Yesterday, DOJ announced that bank zweiplus ag (Bank Zweiplus) and Banca dello Stato del Cantone Ticino (Banca Stato)...more
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
During a meeting with shareholders on April 15, Daniel Sauter, Chairman of Julius Baer Group Ltd., said the bank was at “an advanced stage of talks” with U.S. authorities. The U.S. Department of Justice has been investigating...more
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
BSI of Lugano, Switzerland, became the first bank to earn a non-prosecution agreement under the U.S. DOJ’s Program for Swiss Banks, paying a penalty of $211 million. First announced on August 29, 2013, the program offered...more
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
Authorities in the U.S. continue to crack down on foreign financial institutions that have allegedly aided U.S. taxpayers in evading their tax obligations. On May 19, 2014, Credit Suisse AG pled guilty to conspiracy to aid...more
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
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
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
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
Over the past year, financial institutions have wrestled with the challenges presented by the U.S. Foreign Tax Compliance Act (FATCA). Originally scheduled to take effect in 2013, the U.S. Treasury Department and IRS have...more
As of January 1, 2013, United States banks were required to report to the IRS interest earned by nonresident aliens who are residents of certain foreign countries. The reporting requirement previously existed for accounts...more