A Conversation with Rajiv Gupta on Asia Restructurings
What Are the Drastic Ramifications of the New York State Anti-Money Laundering Actions and Penalty Enforcement?
The Emirate of Dubai in 2024 issued Law No. (1) of 2024 Concerning Tax on Foreign Banks Operating in the Emirate of Dubai. The Law’s passing is an essential step to clarify the applicability of separate tax laws for foreign...more
Federal banking agencies under a second Trump Administration are expected to be more receptive to industry proposals for bank mergers, acquisitions, and related transactions. We've previously explored national trust banks and...more
On November 21, 2024, the Biden Administration announced sweeping new sanctions targeting numerous Russian banks, financial institutions and officials, including one of the largest remaining unblocked Russian banks,...more
Approximately nine million U.S. citizens live or work abroad, and some want to renounce their U.S. citizenship. Many do so with regret but renounce to avoid various financial issues. Others consider themselves “accidental...more
On July 8, 2024, the U.S. Court of Appeals for the Second Circuit reversed, in a summary order, the dismissal of fraudulent transfer claims brought by the purported contract creditor of a shipping company against the shipping...more
On October 1, the OCC released its CRA performance evaluations for September. The OCC evaluated 21 entities, including national banks, federal savings associations and insured federal branches of foreign banks. The assessment...more
The National Taxpayer Advocate 2023 Annual Report to Congress highlights how Taxpayers abroad are underserved and continue to face challenges in meeting their U.S. tax obligations. As a result, the National Taxpayer Advocate...more
The Bankruptcy Code bars certain individuals or entities from filing for bankruptcy protection, generally because they do not reside or have a place of business or property in the United States, fail to satisfy certain debt...more
In most cases seeking recognition of a foreign bankruptcy proceeding in the United States under chapter 15 of the Bankruptcy Code, the foreign debtor's "foreign representative" has been appointed by the foreign court or...more
On December 4, the DOJ announced a deferred prosecution agreement and charges, in the Southern District of New York, a Swiss bank, requiring approximately $122.9 million in restitution for defrauding the U.S. government and...more
Holland & Knight's Venezuela Focus Team invites you to read our Venezuela Update, in which we discuss the latest news, trends and developments in Venezuela that impact the interests of businesses across all industry sectors. ...more
What are the most important elements of estate and tax planning for US expatriates? Are you planning to move out of the United States? Are you a US taxpayer who lives and works outside of the country? What are some of the...more
The U.K. Prudential Regulation Authority is consulting on a proposed rule and policy changes relating to the establishment and maintenance of third-country branches and subsidiaries within ring-fenced banking groups. The...more
On August 29, 2023, the Board of Governors of the Federal Reserve System (FRB), the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (collectively, FBAs) issued requests for...more
A federal court has issued an order granting an injunction that delays the compliance dates for the CFPB’s final rule governing the collection of small business lending data required by Section 1071 of the Dodd-Frank Wall...more
There has been a legal shakeup this summer in the world of “FBARs”—Reports of Foreign Bank and Financial Accounts. New developments have been popping up nearly every week, whether from a court decision, as a result of a...more
On July 27, 2023, the Board of Governors of the Federal Reserve System (FRB), the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, FBAs) issued their long-awaited...more
On June 29, 2023, the IRS published final regulations that provide the appropriate reference rate to be used by a foreign bank that elects to use a published rate to determine the amount of excess interest expense allocable...more
On June 30, 2023, the United States Department of the Treasury (“Treasury”) published Final Regulations as guidance on the transition from the use of the Interbank Offer Rate (IBOR) to the Secured Overnight Financing Rate...more
Today, the Supreme Court of the United States issued three decisions: MOAC Mall Holdings LLC v. Transform Holdco LLC, No. 21-1270: This bankruptcy case involved the interpretation of Bankruptcy Code § 363(m) and its...more
This Article discusses the recent plea agreement between the United States and Danske Bank. It argues that the Department of Justice has advanced a new and evolving theory of liability for foreign banks that access the U.S....more
In this bulletin, we highlight two recent federal court cases in which U.S. taxpayers won major victories against the United States with respect to their obligations to report non-U.S. accounts on FinCEN Form 114 – Report of...more
The U.S. Supreme Court has ruled that the $10,000 penalty for a nonwillful violation of the foreign bank account reporting rules in the Bank Secrecy Act applies on a “per-form” basis, not a “per-account” basis, handing...more
On February 22, the FDIC, Federal Reserve Board, and the OCC announced the publication of a joint notice and request for comment proposing changes to three versions of the Call Report (FFIEC 031, FFIEC 041, and FFIEC 051)...more
A deposited pledge is an arrangement enabling lenders to receive efficient, inexpensive, and readily available collateral from borrowers to secure credit. However, the current legislative arrangement in Israel differentiates...more