The ruling provides a new avenue for parties to bring pre-enforcement challenges to IRS rules and regulations.
Key Points:
..In CIC Services v. IRS, the US Supreme Court allowed a pre-enforcement challenge to an IRS...more
6/17/2021
/ Administrative Procedure Act ,
Anti-Injunction Act ,
CIC Services LLC v IRS ,
Criminal Liability ,
Criminal Penalties ,
Enforcement ,
Federal Jurisdiction ,
Internal Revenue Code (IRC) ,
IRS ,
Notice and Comment ,
SCOTUS ,
Subject Matter Jurisdiction ,
Tax Penalties
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
You have implemented FATCA; what comes next? Will your company be the next witness in a US tax investigation? Financial institutions around the world must now prepare to respond to anticipated inquiries and investigations as...more
8/12/2014
/ Banking Sector ,
Banks ,
Chief Compliance Officers ,
Department of Justice (DOJ) ,
Enforcement ,
FACTA ,
FATCA ,
FFI ,
Financial Institutions ,
Government Investigations ,
IRS ,
OVDP ,
Popular ,
Transparency
United States Department of Justice issues further information on amnesty program for Swiss banks, including details on the selection of an Independent Examiner.
On November 5, 2013, United States Department of Justice...more