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Crackdown on Offshore Tax Evasion Not Slowing Down
The Department of Justice (DOJ) Tax Division and the Internal Revenue Service (IRS) have been ramping up an intense crackdown on offshore tax evasion, and the IRS's reduced resources due to new budget cuts is having no effect on IRS enforcement initiatives in this area.
The government's reach has extended far beyond Switzerland, where it is pursuing criminal investigations of a dozen Swiss banks, and another 100 banks are seeking to avoid criminal investigations and prosecutions. The crackdown has reached jurisdictions including India, Liechtenstein, Luxembourg, Barbados, Hong Kong, Singapore and Israel. (Bank Leumi recently entered into a deferred prosecution agreement with the DOJ, paid a penalty of $270 million, and agreed to identify numerous additional Bank Leumi account holders in the U.S. to the IRS.) Numerous investigations are being pursued in other areas as well, which have not been made public.
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The Article 8 Opt In
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.
Beach Boys Songs Written Decades Ago Triggered Current Quarrel With Lawyers
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Major Differences In UK, U.S. Copyright Laws
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Strategy vs. Tactics: Two Sides of a Difficult Coin
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.
When Is a Repair Structural or Nonstructural Under a Commercial Lease?
A common question that commercial landlords and tenants face is which of them is responsible for a repair to the subject premises. These disputes often center on whether the repair is "structural" or "nonstructural."