After years of inaction, the Internal Revenue Service (IRS) is throwing up obstacles to enjoying the tax advantages of hedge fund-backed reinsurance. On April 24, 2015, the IRS issued a notice of proposed rulemaking titled...more
Tax fraud occurs on a considerable scale that can exceed law enforcement’s ability to detect and punish the conduct. This is true at both the federal and state levels. As of 2015, the Internal Revenue Service (“IRS”) and the...more
On June 18, 2014, the IRS announced significant changes to its current Offshore Voluntary Disclosure Program (OVDP) and to the current version of the IRS Streamlined Filing Compliance Procedures (SFCP). Under the new...more
On May 6, 2014, the Ministry of Finance of Singapore announced that Singapore had agreed in substance on a Model 1 FATCA IGA. Under the IGA, Singapore-based financial institutions will report information on financial accounts...more
On November 29, 2013, the Cayman Islands and the U.S. Signed a FATCA IGA. The Cayman Islands IGA is a Model 1B agreement, meaning that FFIs in the Cayman Islands will be required to report tax information about U.S. account...more
In an update to her December 2012 report, the Taxpayer Advocate has noted that the IRS still has not provided reasonable options for “benign actors”, or taxpayers who inadvertently violated the rules for reporting foreign...more
On June 24, 2013, the U.S. Tax Court disallowed a couple’s deduction for the donation of a conservation easement on the façade of a building to the National Architectural Trust, a qualified charitable organization. The court...more
Carl R. Zwerner of Miami, Florida, is facing nearly $3.5 million in civil penalties for failing to report a Swiss bank account, according to a lawsuit filed by the Justice Department (United States v. Zwerner, S.D. Fla., No....more