CLE on Off-Shore Tax Issues
Compliance with off-shore tax laws has always been complex. In recent years, however, criminal tax investigations have added to this complexity, raising the possibility that lawyers-and their legal fees-may be vulnerable. This all-new video webcast will explore the intricacies of off-shore tax compliance for lawyers and accountants who have clients with interests in foreign bank accounts or other foreign-based entities. It will also be useful to estate planners and business lawyers whose clients reside in multiple jurisdictions or otherwise have investments both within and outside of the United States.
The first part of the presentation, “Required Foreign Financial Reporting,” will be led by Jerald August of Fox Rothschild LLP. He will provide an overview of the current foreign bank and financial account reporting rules under the Financial Crimes Enforcement Network (FinCEN), as well as under new section 6038D regulations and Form 8938 “Statement of Specified Foreign Financial Assets” under the Foreign Account Tax Compliance Act (FATCA). Mr. August will also cover filing obligations of foreign financial institutions or foreign entities in which U.S. taxpayers hold a substantial ownership interest due to FATCA.
The second part of this program, “Government’s Increasing Use of Money-Laundering Offenses as a Prosecutorial Tool For Tax Evasion,” will be led by Ian Comisky of Blank Rome LLP. He will report on recent cases-including the Wegelin Bank asset proceeding in New York-that have raised the specter of a government charging traditional tax offenses as money laundering and seeking the forfeiture of assets. Mr. Comisky will also discuss how the legal landscape now considers as money laundering offenses that were formerly traditional tax charges. He will further investigate the availability of asset forfeiture for violations of these offenses and whether counsel, as well as their fees, are at risk.