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Results: 1-10 of 20

Repayment of embezzled funds is not a deductible business loss

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 3 2011

A New York State Administrative Law Judge has held that a taxpayer cannot claim trade or business losses for embezzled funds that she repaid, and could not receive the benefits of loss carryback provisions

Grand jury indicts Swiss lawyer and banker in tax evasion scheme

  • Katten Muchin Rosenman LLP
  • -
  • USA
  • -
  • April 26 2013

A New York federal grand jury recently indicted a Swiss lawyer and bank executive for their roles in allegedly assisting US citizens with hiding

New Offshore Voluntary Disclosure Program: a carrot without a stick?

  • Morvillo Abramowitz Grand Iason & Anello PC
  • -
  • USA
  • -
  • July 13 2012

Since 2008, the Internal Revenue Service has used both the stick (the threat of criminal prosecution) and the carrot (a series of voluntary disclosure initiatives) to bring taxpayers into compliance with their obligations to report offshore accounts and assets

What does the flap over Romney’s tax returns suggest about disclosure of his Swiss account?

  • Morvillo Abramowitz Grand Iason & Anello PC
  • -
  • USA
  • -
  • August 8 2012

As the “will he or won’t he” controversy continues to swirl around demands that Mitt Romney release multiple years of his federal income tax returns, some commentators have speculated that Governor Romney’s reluctance to produce those returns relates to his Swiss bank account

Final FBAR reporting rules provide relief, but no exemption, for pension plans investing in foreign accounts

  • Pillsbury Winthrop Shaw Pittman LLP
  • -
  • USA
  • -
  • February 28 2011

On February 24, 2011, the Financial Crimes Enforcement Network of the Department of Treasury (FinCEN) issued final rules on FBAR filing requirements applicable to U.S. persons, including U.S. pension plans that invest in foreign financial accounts or who have signature authority over such accounts

Gimme (tax) shelter

  • Day Pitney LLP
  • -
  • USA
  • -
  • January 4 2013

In a split opinion, the U.S. Court of Appeals for the Second Circuit in United States v. Coplan overturned the convictions of two defendants in the Ernst

State taxing authorities have little sympathy for victims of Madoff and other Ponzi schemes

  • Fox Rothschild LLP
  • -
  • USA
  • -
  • October 25 2010

On October 17, 2010, Harold Brubaker, who has written several articles on the subject of Madoff and other Ponzi schemes in The Philadelphia Inquirer, reported that the Pennsylvania Department of Revenue has made it extraordinarily frustrating and difficult for victims of Ponzi schemes to recover state tax refunds for tax payments on income that turned out to be illusory

Federal district court finds promoter of “Aegis” system of “trusts” guilty of conspiracy to defraud and aiding the filing of a false tax return

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • April 16 2010

The defendant in Wasson was found guilty of conspiracy to defraud and of aiding in the filing of a false tax return

Update on offshore bank secrecy directives by the United States and the Internal Revenue Service : "mining the UBS lake" for US tax evaders

  • Fox Rothschild LLP
  • -
  • Switzerland, USA
  • -
  • August 17 2010

At the present time the good people of the Swiss Federal Tax Administration are sorting out which of the thousands of requested names of US persons and account numbers with UBS will be turned over to the United States shortly in accordance with the U.S.-Swiss agreement

Treasury, IRS issue proposed regulations and guidance addressing FBAR reporting requirements for retirement plans

  • Katten Muchin Rosenman LLP
  • -
  • USA
  • -
  • March 5 2010

At the end of February, the Financial Crimes Enforcement Network (FinCEN) bureau of the U.S. Department of the Treasury issued proposed amendments to the Bank Secrecy Act regulations governing Reports of Foreign Bank and Financial Accounts, commonly referred to as “FBAR.”