News & Analysis as of

Reporting Requirements Internal Revenue Service Anti-Money Laundering

Mayer Brown

IRS-CI Announces a New Initiative to Enhance BSA Information-Sharing with Financial Institutions

Mayer Brown on

On March 28, 2025, the Internal Revenue Service (“IRS”)’s criminal investigative arm, IRS Criminal Investigation (“IRS-CI”), announced that it would be implementing a new program called CI-FIRST (Feedback in Response to...more

Haynsworth Sinkler Boyd, P.A.

New Deadlines for FINCEN Compliance Issued

The Corporate Transparency Act (CTA) introduced substantial new reporting obligations for a wide array of corporate entities. Generally, any domestic entity formed by filing documents with a secretary of state or similar...more

Foodman CPAs & Advisors

NTA Addresses Overlap Reporting

On 1/8/25, the National Taxpayer Advocate (NTA) published its 2024 Annual Report to Congress and identified taxpayers’ problems and provided suggestions to further protect taxpayer rights and ease taxpayer burden. “By law,...more

Allen Barron, Inc.

A Foreign Trust Creates Complex IRS Reporting Requirements

Allen Barron, Inc. on

The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more

Buchalter

Historic AML Prosecution, Previously Led by Shareholder Daniel Silva: Wynn Las Vegas Agrees to $130M Penalty in Largest-Ever...

Buchalter on

On September 6, 2024, Wynn Las Vegas (“Wynn LV”) agreed to forfeit over $130 million to resolve a criminal investigation into the gaming giant’s suspected violated federal anti-money laundering (“AML”) laws. Daniel Silva, a...more

Seward & Kissel LLP

Final Tax Rules and Transitional Guidance for Broker Reporting

Seward & Kissel LLP on

The Internal Revenue Service (“IRS”) recently finalized Treasury Regulations (the “Final Regulations”) and published two notices and a Revenue Procedure (the “Transitional Guidance”) for broker reporting of certain...more

Ballard Spahr LLP

IRS Unveils Broad Draft Information Reporting Form for Digital Asset Transactions

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On April 18, the Internal Revenue Service (“IRS”) issued a draft version of Form 1099-DA, a proposed information reporting form regarding certain digital asset sales and exchanges that “digital asset brokers” will need to...more

Downs Rachlin Martin PLLC

Corporate Transparency Act Imposes New Federal Reporting Requirement On Businesses

Background - In January 2021, the United States Congress passed the Corporate Transparency Act (CTA) as part of the Anti-Money Laundering Act of 2020. This law, while intended to prevent criminal actors from hiding and...more

Dickinson Wright

Corporate Transparency Act Compliance Date Is Approaching Quickly

Dickinson Wright on

Although the Corporate Transparency Act (CTA”) was adopted in 2021,  implementation has been delayed while the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”)  established regulations. The deadline,...more

Lowenstein Sandler LLP

Preparing Your Company for FinCEN’s Beneficial Ownership Reporting Requirements

On September 29, 2022, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule implementing the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements...more

Oberheiden P.C.

Tokenization Lawyer – 5 Reasons Why You Might Need One

Oberheiden P.C. on

What is Tokenization? Tokenization is the process of converting an asset into a token on the blockchain. It operates by dividing—or fractionalizing—the ownership of an asset (whether the asset is a piece of real estate or...more

Skadden, Arps, Slate, Meagher & Flom LLP

Cryptocurrency Regulation and Enforcement at the US Federal and State Levels

In recent months, the increased focus on cryptocurrency regulation and enforcement at both the federal and state levels demonstrates the digital currency’s place as an established component of the financial landscape. At the...more

Katten Muchin Rosenman LLP

Agencies and Regulators Focus on AML Compliance for Cryptocurrency Industry

This year, regulators, supported by a slate of new legislation, have focused more of their efforts on AML violations and compliance deficiencies than ever before. As we have written about in the "AML Enforcement Continues to...more

Freeman Law

Do FBAR Penalties Survive Death? A Texas Court Says “Yes”

Freeman Law on

A federal district court in Texas recently took up an interesting FBAR issue: whether civil FBAR penalties survive death?  That is, if a taxpayer/account holder dies after the IRS assesses an FBAR penalty against them, do the...more

Foodman CPAs & Advisors

Upcoming Virtual Currency FBAR and FATCA Reporting Enforcement

Under current FinCEN regulations, a foreign account holding virtual currency is not reportable on the FBAR.  However, FinCEN in its FinCEN Notice 2020-2, proposes amending reports of foreign financial accounts (FBAR)...more

White and Williams LLP

Corporate Transparency Act and Implications for Entity Formation and Transaction Structures

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As the 116th United States Congress came to a close, in its final hours, and skipping weeks of political drama for purposes of this post, the legislative body took the unprecedented step and overrode a presidential veto for...more

Foodman CPAs & Advisors

Taxpayers that have VIRTUAL CURRENCY held in a Centralized Virtual Currency Exchange outside the U.S must file an FBAR and FORM...

On May 30, 2018, the AICPA (American Institute of Certified Public Accountants) wrote a letter to the IRS to obtain further definition and clarity regarding Virtual Currency (VC) FATCA and FBAR reporting requirements....more

Akin Gump Strauss Hauer & Feld LLP

Developments in Cryptocurrency in 2018

• The U.S. Securities and Exchange Commission (SEC) staff made official statements regarding when a token may or may no longer be a security • The SEC continued to bring actions related to cryptocurrency offerings against...more

Foodman CPAs & Advisors

BSA, FinCEN, Treasury and IRS Want to Know: Who is the Ultimate Beneficial Owner (UBO)?

There seems to be a convergence by the Financial Crimes Enforcement Networks (FinCEN), the Treasury Department and the IRS for determining “who is the UBO” of entities. The U.S. Government is determined to enforce financial...more

Foodman CPAs & Advisors

De-Risking 101

Foodman CPAs & Advisors on

Bank Secrecy Act of 1970 - Requires U.S. financial institutions to assist U.S. government agencies to detect and prevent money laundering by keeping records of cash purchases of negotiable instruments, and file reports...more

Holland & Knight LLP

FinCEN Doubles Down on Casinos with Heightened Regulatory Expectations - Casino Managers and Tribal Gaming Commissioners Need to...

Holland & Knight LLP on

For the second time in nine months, Financial Crimes Enforcement Network (FinCEN) Director Jennifer Shasky Calvery has publicly addressed FinCEN's increasing concerns regarding casino compliance with the Bank Secrecy Act...more

Holland & Knight LLP

FBAR Update

Holland & Knight LLP on

The Report of Foreign Bank and Financial Accounts (FBAR) can no longer be filed on TDF 90-22.1, and must be e-filed on Form 114. This alert summarizes developments involving FBAR e-filing and signature authority. They are...more

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