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The ongoing saga of tax refund ownership for bank holding companies
  • Arent Fox LLP
  • USA
  • February 4 2015

The Third Circuit recently weighed into the ongoing debate over the ownership of tax refunds generated by a failed bank in FDIC receivership, but

HSBC India accounts sought by IRS: time running out for IRS voluntary disclosure by HSBC India customers
  • Duane Morris LLP
  • USA
  • April 13 2011

On April 7, 2011, the U.. District Court for the Northern District of California issued an order authorizing the Internal Revenue Service ("IRS") to serve a "John Doe" summons requesting information from one of the world's largest banks, HSBC, regarding U.S. residents who may be using accounts at HSBC in India to evade federal income taxes

Government fails to prove taxpayer “willfully” concealed offshore bank accounts
  • Alston & Bird LLP
  • USA
  • October 20 2010

Under foreign bank account reporting requirements, a U.S. person who has a financial interest in or signature authority over financial accounts in a foreign country where the aggregate value exceeds $10,000 is required to file a Report of Foreign Bank and Financial Accounts

For holders of offshore bank accounts, another domino falls
  • Baker & Hostetler LLP
  • USA
  • September 28 2012

On September 21, 2012, the U.S. Court of Appeals for the Fifth Circuit joined the Seventh and Ninth Circuits in holding that holders of offshore bank accounts have no recourse to the Fifth Amendment privilege against self-incrimination when the government demands that they turn over their offshore bank account records

Press corner
  • Morrison & Foerster LLP
  • USA
  • March 31 2010

The US tax authorities will soon launch another prosecution against a foreign bank for facilitating offshore tax evasion, a la the case against Swiss bank UBS AG, according to an IRS agent speaking with Reuters

Close of landmark Swiss bank litigation marks the "beginning of a global offshore tax evasion probe"
  • Dykema Gossett PLLC
  • Switzerland, USA
  • November 18 2010

On Tuesday, November 16, 2010, after receiving more than 4,000 names of suspected tax evaders, Internal Revenue Service closed legal proceedings against UBS, a Swiss bank that the IRS alleged had assisted United States taxpayers in efforts to hide assets and income

IRS cancellation of indebtedness form is not an "information return" under Section 7434
  • Kelley Drye & Warren LLP
  • USA
  • March 24 2011

When Susan and Robert Cavoto were experiencing financial difficulties, they turned to Susan’s mother, Mary Hayes

Foreign bank account reporting and enforcement update: U.S. files suit against HSBC seeking account records
  • Blank Rome LLP
  • USA
  • April 12 2011

The United States government has opened another front in its campaign against U.S. taxpayers using secret offshore bank accounts to evade their tax responsibilities, with the Justice Department filing a lawsuit seeking the names of Americans believed to be hiding funds in bank accounts at HSBC in India

Court allows foreign tax credits claimed in STARS transaction
  • Steptoe & Johnson LLP
  • USA
  • November 16 2015

The District Court for the District of Massachusetts ruled on Friday that Santander Holdings USA, Inc., (formerly known as Sovereign Bancorp, Inc

IRS and DOJ Use a New Method to Defeat Taxpayers’ Fifth Amendment Argument Against Turning Over Foreign Account Records
  • Baker & Hostetler LLP
  • USA
  • January 4 2016

At virtually every turn, courts have ruled against taxpayers who have asserted their Fifth Amendment privilege against self-incrimination to avoid