BNA INSIGHTS: IRS Offshore Accounts Disclosure Program: A Critical Assessment After One Year
October 5, 2010 in Banking Report · Leave a Comment
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
September 21, 2010 in Banking Report · Leave a Comment
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
August 31, 2010 in Banking Report · Leave a Comment
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
August 31, 2010 in Banking Report · Leave a Comment
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
July 13, 2010 in Banking Report · Leave a Comment
The Department of Justice Tax Division has sent out letters informing at least several individuals with accounts in…
IRS Hoping to Address Many Issues in First Guidance Under Foreign Account Tax Compliance Act
June 4, 2010 in Daily Tax Report · Leave a Comment
Internal Revenue Service Associate Chief Counsel Steven Musher June 3 said his agency is planning to include as many issues as it can in the first wave of guidance on legislation requiring broad…
U.S., 14 Other Nations Sign OECD, Council of Europe Agreement on Cooperation in Tax Matters
May 28, 2010 in Daily Tax Report · Leave a Comment
Fifteen countries, including the United States, May 27 signed an update to a 1988 multilateral pact on administrative cooperation in tax matters that aims to provide a legal framework for…
Senate Passes Financial Reform Bill Affecting Tax Treatment of Derivatives
May 24, 2010 in Daily Tax Report · Leave a Comment
The Senate voted 59-39 late May 20 to pass its version of a financial regulation reform bill that could have an adverse and unintended tax impact on…
House Ways and Means Chair Levin Unveils Amendment to Stop Banks from Impeding U.S. Tax Enforcement Efforts
May 18, 2010 in Banking Report · Leave a Comment
Sen. Carl Levin (D-Mich.) May 11 introduced an amendment to the Senate financial regulatory reform bill (S. 3217) that would provide the Treasury Department broad new authority to impose financial sanctions against jurisdictions…
Developed Country Banks, Offshore Financial Centers Holding Illicit Funds, Group Says
May 14, 2010 in Daily Tax Report · Leave a Comment
Banks in more than a dozen developed countries absorbed from 46 percent to 67 percent of “illicit financial flows” from developing countries from 2002 to 2006, while at least 10 offshore financial centers absorbed…


