As the IRS increases its efforts at combating tax evasion by taxpayers who hide their assets offshore in countries with favorable bank secrecy laws, practitioners at the annual ABA criminal tax institute lobbied for the IRS to extend its popular and effective voluntary disclosure program.
A recent series of decisions in the case Victor Stanley, Inc. v. Creative Pipe, Inc. in the U.S. District Court for the District of Maryland, demonstrate the serious consequences that can arise when parties engage in the intentional spoliation of evidence.
On December 1, 2010, revisions to Federal Rule of Civil Procedure 26 took effect which will have significant implications on the attorney-expert witness relationship. The new changes will limit the amount of expert discovery that is available and should provide for more efficient and cost effective litigation.
On December 7, 2010, the European Union (“EU”) announced an agreement that will require its members to exchange tax information on nonresident citizens in an effort to fight tax fraud. […]
On December 7, 2010, the United States Department of Justice announced that it had reached a $421.2 million settlement agreement with three pharmaceutical manufacturers for alleged violations of the False […]
On December 1, 2010, the Treasury Department announced its goal of finalizing regulations dealing with cancellation of debt income (“COD”) in partnerships contained in Section 108(e)(8) of the internal revenue […]
The FDA has recently issued its annual guidance document agenda. The Annual Guidance Agenda details the topics that the Agency intends to focus on in the upcoming year. While the […]
McNeil, the manufacturer of Tylenol Cold, has asked the U.S. Supreme Court to decide whether federal law, which imposes certain requirements for labeling on makers of over-the-counter (OTC) drugs, preempts […]
On November 30, 2010, the IRS posted to its website two program manager technical advice memorandums (“PMTA”) regarding CDP conferences and short sale situations. A PMTA is a document issued […]
On December 6, 2010, the Financial Crimes Enforcement Network (“FinCEN”) of the United States Department of the Treasury announced a proposed rule that would require non-bank residential mortgage lenders and […]
