Government Dismisses Criminal Tax Case Against UBS, Prompting Questions about IRS’s Next Overseas Target

The U.S. government’s dismissal of a criminal information against the Swiss bank UBS AG that was filed with the U.S. District Court for the Southern District of Florida Oct. 22 has led to questions as to which…

BNA INSIGHTS: The Developing Aftermath of the UBS Affair: A New Tax Order

The high-profile UBS tax evasion case has been especially attractive to the popular press the past…

BNA INSIGHTS: IRS Offshore Accounts Disclosure Program: A Critical Assessment After One Year

Exactly one year ago, the tax world watched as the Internal Revenue Service conducted what may have been the most extraordinarily…

BNA INSIGHTS: Passive-Aggressive: IRS Releases Initial Guidance on FATCA Rules

Any attorney who has practiced law for some period of time has encountered co-counsel or opposing counsel who release a thick set of…

U.S., Switzerland Say Deadline for Processing UBS Accounts Met, Handover Not Yet Done

GENEVA—Both the U.S. and Swiss governments said Aug. 26 that Switzerland has met its obligations under a landmark August 2009 agreement with the United States to review some 4,450 secret accounts held by U.S. taxpayers with Swiss banking giant UBS, but Swiss officials admitted…

IRS Unveils Comprehensive Guidance on Foreign Bank Reporting, Disclosure

The Internal Revenue Service Aug. 27 unveiled eagerly awaited guidance on the implementation of the Foreign Account Tax Compliance Act (FATCA), which imposed a host of new requirements…

Justice Department Investigating HSBC Account Holders for Not Disclosing Assets, Practitioners Say

The Department of Justice Tax Division has sent out letters informing at least several individuals with accounts in…

BNA INSIGHTS: Foreign Account Tax Compliance: New U.S. Rules Requiring Reporting on Certain Foreign Accounts

This legislation is a direct result of the focus by the United States and other industrialized and developing countries on combating offshore tax evasion and recouping much needed…

IRS Seeks Comments on Implementing New Foreign Account Tax Compliance Act; Stakeholders Weigh in

The Internal Revenue Service April 7 asked the tax community for comments on how best to implement provisions of the Foreign Account Tax Compliance Act, recently signed…

Foreign Bank Reporting Provisions in New Job Creation Law Seen Changing Withholding Tax Landscape

President Obama’s signature on major new jobs legislation (Pub. L. No. 111-147; H.R. 2847) March 18 puts in place a host of requirements for foreign banks to report and…

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