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The year 2010 will go down in history as the year the great wall of Swiss bank secrecy officially collapsed. On June 17, 2010, the Swiss Parliament ratified the settlement agreement between the U.S. Department of Justice (DOJ) and UBS AG, and the process of turning over the names and Swiss banking information of approximately 4,450 U.S. taxpayers began. For taxpayers who missed the opportunity to participate in the Internal Revenue Service's special Off-shore Voluntary Disclosure Program (OVDP), which ended in October 2009, the chance of criminal prosecution is high.
This article addresses the potential penalties facing taxpayers with undisclosed foreign accounts and focuses in particular on the draconian penalties being issued across the board for failure to file Form TDF 90-22.1, Report of Foreign Bank and Financial Accounts ' commonly referred to as an “FBAR.” And we also discuss a recent decision out of the Eastern District of Virginia, which provides some small hope that the government will begin to exhibit a bit of flexibility in its approach to FBAR penalties.
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The Article 8 opt-in election adds an additional layer of complexity to the already labyrinthine rules governing perfection of security interests under the UCC. A lender that is unaware of the nuances created by the opt in (may find its security interest vulnerable to being primed by another party that has taken steps to perfect in a superior manner under the circumstances.
This article highlights how copyright law in the United Kingdom differs from U.S. copyright law, and points out differences that may be crucial to entertainment and media businesses familiar with U.S law that are interested in operating in the United Kingdom or under UK law. The article also briefly addresses contrasts in UK and U.S. trademark law.
There's current litigation in the ongoing Beach Boys litigation saga. A lawsuit filed in 2019 against Nevada residents Mike Love and his wife Jacquelyne in the U.S. District Court for the District of Nevada that alleges inaccurate payment by the Loves under the retainer agreement and seeks $84.5 million in damages.
With each successive large-scale cyber attack, it is slowly becoming clear that ransomware attacks are targeting the critical infrastructure of the most powerful country on the planet. Understanding the strategy, and tactics of our opponents, as well as the strategy and the tactics we implement as a response are vital to victory.
The real property transfer tax does not apply to all leases, and understanding the tax rules of the applicable jurisdiction can allow parties to plan ahead to avoid unnecessary tax liability.