This panel discussed topics flowing from recent global cooperation (FATCA/CRS) and enforcement by US tax authorities.
The topics included:
- Immigration and expatriation – planning, strategies, residency, and estate issues.
- High-level summary of offshore enforcement activities (OVDP/streamline numbers, current issues in streamline submissions).
- FBAR developments – audit/appeals/litigation activity.
- Civil offshore enforcement tools and increased cooperation among foreign jurisdictions.
- Criminal offshore enforcement update (current statistical information; focus on “leaver” cases from Swiss Bank Program; and sentencing data).
Mark E. Matthews, Partner, Caplin & Drysdale, Washington, DC
Caroline D. Ciraolo, Partner, Kostelanetz & Fink, LLP, Washington, DC
Amanda P. Varma, Partner, Steptoe & Johnson LLP, Washington, DC
Lowell D. Yoder, Partner, McDermott Will & Emery LLP, Chicago, IL
Natalia Velez, International Tax Partner, MGO LLP, Los Angeles, CA
John Cardone, Director, Withholding and International Individual Compliance, LB&I, Internal Revenue Service, Washington, DC