California adopts tax amnesty covering, among other things, income from previously unreported foreign bank accounts *

USA - March 30 2011
On March 24, 2011, Governor Jerry Brown signed SB 86 into law.

Co-authors: Eugene Illovsky.

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FinCEN issues final FBAR rules *

USA - February 25 2011
The Financial Crimes Enforcement Network ("FinCEN") on February 24, 2011 issued final rules (the "Rules") that amend the regulations under the Bank Secrecy Act (the "BSA") regarding Form TD F 90-22.

Co-authors: Michelle Jewett, Eugene Illovsky, Edward L. Froelich.

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Expanded whistleblower regulations, schedule UTP and corporate governance: a potent combination of IRS strategies *

USA - February 17 2011
The Internal Revenue Service's interest in encouraging and incentivizing whistleblowers appears unlikely to subside.

Co-authors: Eugene Illovsky, Edward L. Froelich.

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IRS unveils 2011 Offshore Voluntary Disclosure Initiative *

USA - February 14 2011
On February 8, 2011, the IRS unveiled the 2011 Offshore Voluntary Disclosure Initiative ("OVDI"), pursuant to which taxpayers may come forward, through August 31, 2011, to report previously undisclosed foreign accounts, assets, and income.

Co-authors: Remmelt A. Reigersman, Edward L. Froelich.

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IRS considers new partial amnesty program for offshore accounts: strategic considerations for taxpayers *

USA - January 26 2011
Taxpayers who hold any interest in, or signature authority over, a foreign bank account are required to indicate that on Schedule B of the Form 1040, and also file with the Treasury a Report of Foreign Bank and Financial Accounts, Form TD F 90-22.

Co-authors: Eugene Illovsky, Edward L. Froelich.

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