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Tax Evasion International Tax Issues

Allen Barron, Inc.

Are you Thinking of Moving to Another Country - A Few Things to Consider

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Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more

BakerHostetler

Crypto + Evasion = Jail - The Government’s Old Math for a New Technology

BakerHostetler on

The Department of Justice (DOJ), IRS Criminal Investigations (CI) and international tax authorities continue to prosecute tax abuses related to digital asset transactions. In imposing a multiyear prison sentence in a recent...more

Cadwalader, Wickersham & Taft LLP

EU List of Non-Cooperative Jurisdictions Expanded

On 14 February, the EU Council added four jurisdictions (the British Virgin Islands, Costa Rica, Marshall Islands and Russia) to the list of non-cooperative jurisdictions (Annex I) (the “EU Blacklist”)....more

BakerHostetler

Global Tax Enforcement Group Provides NFT Red Flag Guidance

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Key Takeaways - ..The Joint Chiefs of Global Tax Enforcement (J5) issued its first intelligence bulletin providing guidance to banks, law enforcement partners and private investigators regarding indicators of potential...more

Cadwalader, Wickersham & Taft LLP

EU Directive Targets 'Shell' Companies

On December 22, 2021, the European Commission published proposals for a Directive which targets the perceived misuse of “shell” entities for tax purposes. The draft of the Directive proposes a common minimum substance test...more

Freeman Law

The IRS’s Renewed Focus on Abusive Trust Arrangements

Freeman Law on

Taxpayers have long utilized trust arrangements for the transfer of wealth to beneficiaries or for the protection of assets from creditors.  Generally, there is nothing nefarious about these types of arrangements.  Rather,...more

Freeman Law

Is My Foreign Retirement Account Subject to IRS Information Return Reporting (FBAR, 3520, etc.)?

Freeman Law on

United States citizens and residents[i] are subject to federal income tax on their worldwide income. For example, even if a United States citizen permanently relocates to a foreign country, he or she will generally continue...more

Gray Reed

Non-Willful FBAR Penalties Will be Much Higher in the Fifth Circuit

Gray Reed on

On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account...more

A&O Shearman

Global Tax Insights: Uncertain tax positions: preparing for further tax disclosure

A&O Shearman on

The UK government is pressing ahead with its proposal to require large businesses to notify their “uncertain tax positions” to HMRC. ...more

Katten Muchin Rosenman LLP

The UK Government and HMRC's Efforts to Clamp Down on Promoters of Tax Avoidance

Tax avoidance is the process of manipulating tax rules to reduce the amount of tax payable and obtaining a financial advantage that was never the intention of the legislation. A typical example of tax avoidance involves the...more

Carlton Fields

Les Obligations Fiscales et Formulaires Fiscaux aux États-Unis

Carlton Fields on

Qu’est-ce que le Foreign Account Tax Compliance Act (« FATCA ») ? Depuis plusieurs années, l’IRS mène une campagne agressive contre la fraude fiscale internationale et la nondéclaration de comptes bancaires et autres...more

Morgan Lewis

Sovereign Wealth Funds Update: Tax Aspects of Private Fund Investments: Selected US, EU, and UK Considerations in the Current...

Morgan Lewis on

Despite the market disruption caused by the COVID-19 pandemic, sovereign wealth funds continued to make significant capital commitments to private funds during 2020, on a global basis. As the world emerges from the pandemic,...more

Jones Day

Restoration of Crown Preference and Erosion of the English Floating Charge

Jones Day on

With effect from December 1, 2020, Her Majesty's Revenue and Customs ("HMRC") ranks ahead of floating charge holders and unsecured creditors with respect to recovering certain pre-insolvency taxes from an insolvent business...more

Proskauer - Tax Talks

Cayman Islands removed from the EU blacklist of non-cooperative jurisdictions for tax purposes

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The European Council has announced its decision to remove the Cayman Islands from the EU list of non-cooperative jurisdictions for tax purposes. In February we reported on Cayman’s inclusion on the list and our expectation...more

McDermott Will & Emery

Weekly IRS Roundup February 17 – 21, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 17 – 21, 2020. February 18, 2020: The IRS issued a revenue ruling providing various...more

McDermott Will & Emery

How CCO Reasonable Prevention Procedures Can Help You Mitigate DAC6 Penalties

McDermott Will & Emery on

Corporate criminal offences (CCOs) under Part 3 Criminal Finances Act 2017 (CFA) are increasingly coming under the spotlight of the UK tax authorities. In a 10 February 2020 press release published in response to a Freedom of...more

Proskauer - Tax Talks

Cayman Islands added to the EU blacklist of non-cooperative jurisdictions for tax purposes

Proskauer - Tax Talks on

On 18 February 2020, the ECOFIN committee of finance ministers of the EU resolved to add the Cayman Islands to the EU blacklist of non-cooperative jurisdictions for tax purposes. Their reasoning was short...more

Ballard Spahr LLP

United States “Beats” Switzerland as a Perceived Global Haven for Money Laundering and Tax Evasion

Ballard Spahr LLP on

The Cayman Islands Receive “Top Honors.”  But, Global Financial Transparency is Reportedly Improving in General - The United States has overtaken Switzerland as a financial secrecy haven, according to the latest rankings –...more

Dechert LLP

HMRC’s Implementation of EU Mandatory Tax Disclosure Rules

Dechert LLP on

HMRC has released a consultation document in respect of its draft regulations implementing the EU mandatory tax disclosure rules that will apply from 1 July 2020 to intermediaries and relevant taxpayers in relation to...more

Holland & Knight LLP

Colombia Propone Cambios a las Regulaciones Tributarias - Una Mirada a los Principales Cambios Propuestos por la Ley de...

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En términos generales, los cambios impositivos propuestos más grandes de Colombia tendrían un impacto en el Impuesto sobre las ventas (IVA), la creación de un impuesto unificado denominado SIMPLE, la emisión del impuesto a la...more

Foodman CPAs & Advisors

Out of Compliance Taxpayers: Beware of new IRS-Programs!

The IRS-Criminal Investigation Unit (IRS-CI) is the Criminal Law Enforcement Arm of the IRS. Its conviction rate of over 90% is one of the highest in federal law enforcement. Those convicted pay taxes, penalties and...more

Foodman CPAs & Advisors

Cumplimiento Fiscal Internacional

Detectar, disuadir y responder al incumplimiento internacional son desafíos clave que enfrentan las autoridades tributarias de todo el mundo. El incumplimiento fiscal internacional es un problema significativo reconocido por...more

Sheppard Mullin Richter & Hampton LLP

New Tax Information Exchange Agreement Between the United States and Argentina

The governments of Argentina and the United States signed on December 23rd, 2016, a new tax information exchange agreement (“TIEA”). Jack Lew, U.S. Treasury Secretary, stated that the TIEA will allow for important...more

Robins Kaplan LLP

Your daily dose of financial news The Brief – 4.6.16

Robins Kaplan LLP on

Talk about a regulation with teeth. Within days of the Treasury Department announcing new rules meant to discourage corporate tax inversion deals, Pfizer and Allergan announced they were scrapping their planned $152 billion...more

Latham & Watkins LLP

Bandfield Confirms Aggressive FATCA Enforcement Tactics

Latham & Watkins LLP on

On Sept. 9, 2014, in U.S v. Robert Bandfield et al., federal prosecutors in the Eastern District of New York announced the indictment of a U.S. citizen and others, including offshore corporate service providers (CSPs) and...more

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