The program for non-prosecution agreements for Swiss Banks is
largely settled. However, in a ruling by the Swiss Courts a few
weeks ago, a bank in the Canton of Ticino was prohibited from
releasing the names of two Swiss attorneys who acted as proxies for
American customer accounts. Further, the name of a law firm who
assisted U.S. persons was also withheld.
The participating bank was in the process of complying with
the Settlement Program and it intended to release the names of the
lawyers and law firm as part of the disclosure process, but a suit
followed to block the release of the information.
Ultimately, the Swiss court held that the names should be
protected from disclosure under its laws. The Court also found that
the U.S. lacks similar legislation to provide adequate data
Last week, U.S. authorities have indicated that by mid-November
an expanded list of banks and facilitators would be published. That
list mandates a 50% penalty, as opposed to a 27.5% penalty, for
U.S. persons entering the Offshore Voluntary Disclosure Program.
For those U.S. persons who have not yet come into compliance with
their U.S. tax obligations, time is growing short.
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In case you missed our webinar “The 2016 Presidential and Congressional Elections: Impacts on DoD’s Technology Innovation Initiative” hosted by Dentons’ Silicon Valley Institute on Government and Technology on November 17, 2016, a recording is available here.
The discussion, moderated by the Chicago Bar Foundation (CBF), will feature Allstate GC Susie Lees, Dentons Pro Bono Partner Ben Weinberg, and Allstate/Dentons Criminal Records Fellow Nikki Donnelly from Cabrini Green Legal Aid. The panel, part of the CBF's ongoing Leadership Circle program, will focus on the ongoing Allstate/Dentons Pro Bono clemency project and best practices that can be applied by in-house departments and law firms to address serious needs in the community.
On October 5th, 2016, the Internal Revenue Service and Treasury Department published final, temporary and reproposed regulations1 under Sections 707 and 752 of the Internal Revenue Code of 1986, as amended.
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