Isle of Man: DQ Hosts Landmark Global Tax Enforcement Conference
Last Updated: 4 August 2014

Leading Isle of Man law firm, Dougherty Quinn ("DQ") hosted a landmark Global Tax Enforcement conference in July 2014 aimed at senior management of Isle of Man's financial services businesses.

The conference was organised by DQ together with global law firm Latham & Watkins and US firm Rosenberg Martin Greenberg ("RMG"). The aim of the conference was to provide delegates with an understanding of how international governments pursue tax investigations, what best practices can be implemented on a 'going forward' basis to prepare for such an investigation and the implications of various strategies for handling and meeting the challenges of an investigation.

A key message from the conference was that with the implementation of FATCA from 1 July 2014 and the forthcoming Common Reporting Standard, the financial services industry is standing at the bottom of an inexorable upward curve in global tax enforcement.

Latham & Watkins provided three leading lawyers to the speaking panel, Miriam Fisher, Brian McManus and Chad Nardiello, all from their Washington DC office. The Latham speakers were joined by Caroline Ciraolo a partner with RMG in Baltimore, Maryland who is also widely acknowledged as a leading lawyer in tax controversy and investigations.

In addition, DQ was delighted to welcome Lynda Jones to the Isle of Man for our conference. Lynda is a senior analyst with the US Internal Revenue Service's Criminal Investigation Division, Washington DC. Lynda spoke openly and honestly about the IRS' approach to investigations and to the level of co-operation which is expected from financial institutions in the Isle of Man in the event of an investigation.

The implications of a Tax Information Exchange Agreement ("TIEA") request for an Isle of Man financial services provider were examined by the Deputy Assessor of Income Tax, Colin Goodwin and Annemarie Hughes head of DQ's trusts & private client team. Particular attention was paid to the process by which a TIEA request is served on an Isle of Man business and the common pitfalls that can occur in responding to such requests. DQ's head of regulatory & compliance services, Sinead O'Connor, spoke about the importance of remembering regulatory obligations in the context of a request being served.

The conference certainly brought an important area of compliance to the fore for delegates with the unanimous feedback from delegates being that the conference was a fantastic event. An interesting theme in some of the feedback was the remark that delegates found the conference "excellent, but scary".

The message to industry therefore is: take global tax enforcement seriously; information is now, more than ever, at the fingertips of foreign authorities; and it is only a matter of time before you are engaged, in some manner, in an investigation. Be prepared.

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