News & Events

November 6, 2013

Update on FBARs FATCA OVDI and Emerging Trends in Cross-border Tax Enforcement

Although IRS is holding out a velvet glove by encouraging noncompliant taxpayers to come into compliance, it is showing no mercy in going after other taxpayers still seeking to hide wealth offshore.

The U.S. federal government continues to view offshore tax evasion as a major contributor to the tax gap. As a consequence, the government has been intensifying international enforcement efforts, specifically targeting U.S. persons with undisclosed foreign accounts or holdings in an effort to encourage more compliance. After breaching the formerly impenetrable wall of bank secrecy in Switzerland, the government is now relentlessly pursuing U.S. holders of undisclosed accounts not only in Europe, but also in Asia where offshore private banking is increasingly migrating. Given these ongoing enforcement activities, U.S. taxpayers are finding it increasingly difficuh, as weU as perilous, to hide wealth offshore. As a result of taxpayers that have come forward to date and voluntarily disclosed their offshore holdings (over 39,000 as of December 2012),'' the government is engaged in extensive data mining, sifting throughleads and other information gleaned through these disclosures as well as informants and other sources to widen the net. Armed with this information, the government is increasing the stakes by pursuing criminal charges against private client advisors at foreign banks that have facilitated or assisted U.S. persons in hiding wealth offshore. Most recently, the government successfully prosecuted a centuries-old Swiss bank for conspiring to help U.S. taxpayers hide accounts offshore notwithstanding that that the bank had no affiliate or physical presence in the U.S. As a practical result, the bank has been essentially shut down. 

DOWNLOAD FULL ARTICLE >

News

January 2, 2018

3 Paley Rothman Attorneys Named to “Best Lawyers” List by Washingtonian

Glenn Cooper, Deborah Cohn, and Michelle Chapin were all selected to Washingtonian's "Best Lawyers" list for 2017.

Read More

Blog

Are Your Leave Policies Creating Unintended Tax Issues? Part II: Leave Cash Out

Did you know that leave cash out programs can cause tax issues for employees if they aren’t properly structured?

Read More

Resource Center

Paley Rothman shares this library of resources with clients and friends of the firm to help them stay ahead of legal and business developments and trends. Here, you will find helpful tips and tools written by our attorneys and relevant to our areas of practice.

Read More