by Lynam Knott | Mar 29, 2017 | Aggressive Tax Positions, Offshore Assets, Taxpayer Underpayment, Uncertain Tax Positions
A recent study by the Institute on Taxation and Economic Policy details how Fortune 500 Companies are holding a record $2.6 trillion offshore, thereby avoiding $767 billion in U.S. taxes. While we believe much of this amount is the result of lawful tax planning...
by Lynam Knott | Mar 14, 2016 | Administration of Claims, Administration of Whistleblower Claims, Guidance, Offshore Assets, Whistleblower Awards
Today the Tax Court released its opinion in Whistleblower 22716-13W v. Commissioner, holding that FBAR civil penalties are not “additional amounts” within the meaning of section 7623(b)(5)(B), and they are not “assessed, collected, … [or] paid...
by Lynam Knott | May 12, 2014 | Department of Justice, Offshore Assets, Voluntary Disclosure Initiative, Whistleblower Awards
Kathryn Keneally, Assistant Attorney General, Tax Division of the Department of Justice, acknowledged that the Department of Justice had used information provided by whistleblowers in tracking down unreported offshore bank accounts held by United States citizens while...
by Lynam Knott | Feb 4, 2014 | Aggressive Tax Positions, Offshore Assets, Uncertain Tax Positions
Bloomberg reporters Alex Barinka and Jesse Drucker just wrote an interesting article about how one large multinational is using its tax haven structures, which are typically put in place to supercharge foreign earnings by moving them to low tax jurisdictions through...
by Lynam Knott | Jan 22, 2014 | Administration of Whistleblower Claims, Offshore Assets, Uncertain Tax Positions
Last week the Canada Revenue Agency (“CRA”) formally announced a whistleblower program for reporting Canadian tax fraud. Our contacts in Canada have told us that this measure has been in the works for a long time. For now the details remain a...
by Lynam Knott | Jan 13, 2014 | Department of Justice, Offshore Assets, Taxpayer Underpayment
Last week a Swiss Federal Administrative Court rejected a U.S. government request for banking data on U.S. clients of Swiss bank Julius Baer. This ruling related to a group request for U.S. taxpayers with undisclosed accounts filed on a no-name basis. ...
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