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.
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2010-12-15 11:23:452025-12-09 13:46:50With Offshore Tax Evasion an IRS Top Priority, Practitioners Seek Extension of 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.
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2010-12-15 11:20:312025-12-09 13:44:44Victor Stanley, Inc. v. Creative Pipe, Inc. A Lesson in the Consequences of 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.
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2010-12-13 09:37:392014-11-10 18:22:38Revision to Federal Rule of Civil Procedure 26 Broadens Work Product Protections for Expert Communications with Attorneys
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. […]
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2010-12-10 16:58:232025-12-09 13:44:19EU Ministers Agree to Legislation Aimed At Ending Bank Secrecy Laws of Member States
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 […]
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2010-12-09 16:27:172014-11-10 18:22:38Three Pharmaceutical Manufacturers Agree To Pay $421.2 Million In False Claims Act Settlement
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 […]
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2010-12-09 16:26:162014-11-10 18:22:38Treasury Department Moving Closer to Finalizing Rules on COD Income for Partnerships
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 […]
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2010-12-08 08:28:262025-12-09 13:43:18IRS Issues PMTAs Regarding Financial Data Requests At CDP Conferences, Lien Discharge in Short Sale Situations
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 […]
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2010-12-08 08:24:122025-12-09 13:43:00FinCEN Proposes AML Plan for Non-Bank Mortgage Lenders and Originators
With Offshore Tax Evasion an IRS Top Priority, Practitioners Seek Extension of Voluntary Disclosure Program
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.
Victor Stanley, Inc. v. Creative Pipe, Inc. A Lesson in the Consequences of Spoliation of Evidence
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.
Revision to Federal Rule of Civil Procedure 26 Broadens Work Product Protections for Expert Communications with Attorneys
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.
EU Ministers Agree to Legislation Aimed At Ending Bank Secrecy Laws of Member States
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. […]
Three Pharmaceutical Manufacturers Agree To Pay $421.2 Million In False Claims Act Settlement
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 […]
Treasury Department Moving Closer to Finalizing Rules on COD Income for Partnerships
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 […]
FDA Publishes Agenda for Upcoming Guidance Documents
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 Brings Failure-to-Warn Preemption Issue to Supreme Court
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 […]
IRS Issues PMTAs Regarding Financial Data Requests At CDP Conferences, Lien Discharge in Short Sale Situations
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 […]
FinCEN Proposes AML Plan for Non-Bank Mortgage Lenders and Originators
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 […]