ArticleData Protection And The Swiss – DOJ Settlement ProgramThe program for non-prosecution agreements for Swiss Banks is largely settled.United StatesTaxDentons
ArticleIRS Report Announces Major Increase In Criminal Investigations For 2013IRS Criminal Investigation announced the release of its 2013 annual report, which reflected a significant increase in criminal investigations.United StatesTaxBakerHostetler
ArticleNext Up: Singapore? Summonses Could Hit More Global Financial InstitutionsA recent summons showdown with UBS shows that DOJ and the IRS are far from done with offshore enforcement efforts, and are expanding those efforts beyond Europe.United StatesTaxDentons
Article2017 US Tax Filing NewsAs we head into a new year, some tax reporting news to keep in mind.United StatesTaxDentons
ArticleTaxpayer Advocate Recommends Ways For IRS To Simplify Foreign Asset ReportingThe National Taxpayer Advocate made three specific recommendations to the IRS to try to simplify the process for reporting foreign assets.United StatesTaxBakerHostetler
ArticleU.S. Supreme Court Refuses To Hear Challenge To FATCAThe U.S. Supreme Court has declined to hear an appeal from the U.S. Court of Appeals' ruling in the Crawford case, in which the constitutionality of FATCA was unsuccessfully argued.United StatesTaxStikeman Elliott LLP
ArticleFacebook Battles IRS In Summons Enforcement CaseFacebook is in a protracted battle with the IRS related to its off-shoring of IP to an Irish affiliate. The IRS issued an administrative summons for the documents, and Facebook has refused to comply.United StatesTaxMcDermott Will & Emery
ArticleLeak Of 1.3 Million Files From Bahamas Corporate Registry Provides Yet Another Starting Point For Government InvestigationsFive months after the Panama Papers leak of offshore client files, the ICIJ have released data from the corporate registry in the Bahamas pertaining to approximately 1.3 client million files. United StatesTaxDentons
ArticleBrattle Report Highlights The Economic Impact Of The Offshore Affiliate Reinsurance TaxA report co-authored by economists at global consulting firm The Brattle Group finds that newly-proposed tax legislation aiming to defer the recognition of affiliated offshore reinsurance for U.S. tax purposes will negatively impact businesses and consumers in the United States.United StatesInsuranceThe Brattle Group, Inc.
ArticleIRS Issues Final Regulations On PFICsThe IRS and Treasury published final regulations (T.D. 9806) that provide guidance on determining ownership of a passive foreign investment company (PFIC)...United StatesTaxGrant Thornton LLP
ArticleIRS Updates FATCA FAQsThe GIIN assigned as a result of this registration option then instructs IDES to route transmissions directly to the IRS.United StatesTaxMcDermott Will & Emery
ArticleThe Dirty Dozen – Top Concerns For 2017With the tax filing season now open, the IRS has listed its top 12 tax scams and warned U.S. taxpayers that participation in these prohibited activities could result in civil and criminal tax exposure.United StatesTaxDentons
ArticleUS Announces Changes To The Offshore Voluntary Disclosure ProgramsThe IRS announced major changes to its offshore voluntary compliance programs, resulting in new guidance for taxpayers overseas and those in the US.United StatesTaxWithers LLP
ArticleCountry Risk: IllustratedLast time, we wrote about "country risk"; i.e., the risk a company takes by doing business in a different country, where laws might be different from what you might expect in your home country. United StatesWealth ManagementDechert
ArticleI Have GIIN. Now What?By now, if you are a "foreign financial institution" for purposes of FATCA, you probably have registered with the IRS.United StatesTaxHerrick, Feinstein LLP
ArticleIRS Issues John Doe Summons For Hidden AccountsThe US Government’s recent crackdown on offshore tax evasion shows no sign of slowing down and appears to be expanding to include new jurisdictions. United StatesTaxA&O Shearman
ArticleDoes The Increased Fee For Renouncing US Citizenship Indicate A Change In Attitude Toward Expatriates?Uncle Sam just managed to dig out a quarter hiding in his couch. Or maybe his patience is just running thin with renouncers.United StatesTaxMoodys Private Client Law