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March 15, 2022
FBAR Penalties - On March 8, 2022, the Southern District of New York issued its Opinion in the case of United States v. Schik, No. 20-cv-0221 (MKV), 2022 U.S. Dist. Lexis 41148...
February 25, 2022
General Overview on HPP Law: The Government of Indonesia issued Law No. 7 of 2021 on Harmonization of Taxation Regulation (Harmonisasi Peraturan Perpajakan or "HPP Law")...
February 10, 2022
For one reason or another, I had several calls last year with attorneys and others regarding IRS Streamlined Filing Compliance Procedure submissions gone wrong. In most cases, it was...
February 9, 2022
In civil and in criminal cases, the Government must generally act within a certain prescribed time to take action against taxpayers. In legal parlance, this period of time is known as...
January 24, 2022
When it comes to international tax and offshore compliance, one of the most popular offshore tax amnesty programs is the Streamline Filing Compliance…
January 17, 2022
When it comes to international tax amnesty and voluntarily disclosing previously unreported foreign accounts, assets, investments, and income — there…
January 13, 2022
This morning, I woke up to news in the Wall Street Journal that indicated that the United States and the Republic of Malta had entered into a Competent Authority Agreement (“CAA”)....
January 11, 2022
The "Report of Foreign Bank and Financial Accounts" (FBAR) penalty has been the subject of much litigation. This Holland & Knight alert focuses on the non-willfulness element of 31...
December 21, 2021
At the end of 2018, the Internal Revenue Service discontinued the Offshore Voluntary Disclosure Program (OVDP). Then, at the end of 2018 and early…
November 25, 2021
On 29 October 2021, the Government of the Republic of Indonesia has officially promulgated Law No. 7 of 2021 on Harmonization of Tax Regulations (“Law…