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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Join Dentons and scientific experts from our affiliate Technology Sciences Group Inc. for an overview of the Toxic Substances Control Act (TSCA), including the significant changes made by the Lautenberg Chemical Safety Act (LCSA), which amended TSCA on June 22, 2016.
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The Treasury Department's Financial Crimes Enforcement Network (FinCEN) announced an automatic six-month extension for taxpayers required to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).
One of the most publicized and long-awaited business provisions contained in the Omnibus Budget Reconciliation Act of 1993, P.L. 103-66, 107 Stat. 312 (1993) (the "1993 Act") was section 197 of the Internal Revenue Code of 1986 (the "Code"), which governs the tax treatment of acquired intangible assets. However, section 197 cannot be analyzed in isolation. Since it comes into play whenever there is an allocation of consideration to an amortizable section 197 intangible, a basic understanding of
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