RQC Group | European Union, United Kingdom, USA | 16 Jan 2024
A warm welcome to our clients and friends, and we hope you have had a good start to 2024. This newsletter covers regulatory developments from the…
Baker McKenzie | USA | 30 Nov 2023
Two recent tax controversies demonstrate the authority of US courts in situations where a taxpayer's assets are held in a country different than the…
Gide Loyrette Nouel | France, USA | 9 May 2023
Les récentes évolutions en matière de déclaration de comptes bancaires et d'actifs financiers étrangers - ou Report of Foreign Bank and Financial…
Gide Loyrette Nouel | France, USA | 9 May 2023
This alert discusses recent developments with respect to the FBAR (Report of Foreign Bank and Financial Accounts). Pursuant to the Bank…
Davies Ward Phillips & Vineberg LLP | USA | 22 Mar 2023
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…
Dentons | USA | 16 Mar 2023
On February 28th, the U.S. Supreme Court decided that the Bank Secrecy Act’s (the “BSA”) $10,000 penalty for the nonwillful failure to file a Report…
Baker McKenzie | USA | 13 Mar 2023
On 28 February 2023, the US Supreme Court held that the USD 10,000 penalty for nonwillful failure to file an FBAR applies per form, not per account…
Frost Brown Todd LLP | USA | 8 Mar 2023
Many CPAs and lawyers do not know the difference between conduct that is tax avoidance versus conduct that is criminal tax evasion. There is a big…
Golding & Golding, International Tax Lawyers | USA | 26 Dec 2022
As 2022 comes to a close and we head into 2023, foreign accounts compliance (FBAR) remains at the forefront of IRS international tax compliance…
Golding & Golding, International Tax Lawyers | USA | 26 Dec 2022
As we come to the close of 2022, there have been several FBAR rulings that are helping shape how the IRS will enforce compliance for years to come…