Section 6751(b), designed to ensure supervisory oversight amid rising penalty assertions in settlement negotiations, has been contentious due its ambiguity, and the final regulations may not resolve the debate....more
While FBAR reporting rules are frequently misunderstood, US persons have several options to correct mistakes, before the government learns of the non-compliance.
June 30th is the annual deadline for filing a Foreign...more
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
Indictment demonstrates the strength of US law enforcement efforts to combat offshore fraud and is the first to charge a FATCA violation.
On September 9, 2014, in US v. Robert Bandfield, et al., federal prosecutors in...more
9/16/2014
/ Conspiracies ,
Enforcement Actions ,
FATCA ,
FATCA Timeline ,
Fraud ,
Indictments ,
Investment Adviser ,
Money Laundering ,
Offshore Companies ,
Reporting Requirements ,
Securities Fraud ,
Tax Evasion ,
Third-Party Service Provider
Miriam Fisher, global Co-chair of the firm's Tax Controversy Practice, focuses her practice on federal tax controversy and litigation, including complex civil and criminal tax matters. Fisher spoke at the November 6, 2013...more