The Customer Due Diligence (“CDD”) regulations issued by the Financial Crimes Enforcement Network (FinCEN) became effective on May 11, 2018. The regulations enacted under the Bank Secrecy Act clarify customer due diligence requirements for banks and other financial institutions. These rules are part of an international effort to combat the use of legal entities such as corporations, limited liability companies, and partnerships from financers of terrorism, money launderers, tax evaders, and other financial criminals.» Read More
With the trial of Paul Manafort in the news, I’ve been thinking of the numerous conversations I have had with clients about properly disclosing foreign financial assets. Among other counts, Paul Manafort is charged with concealing foreign payments and offshore accounts from the U.S.» Read More
In a surprising twist of events, the Ninth Circuit Court of Appeals withdrew their recent transfer pricing decision against Altera Corp.1 The Ninth Circuit previously upheld Treasury regulations regarding the criteria for a cost-sharing arrangement to be considered qualified and thus avoid an IRS adjustment. » Read More
The IRS scored a major victory in the recent transfer pricing case, Altera Corp. & Subsidiaries v. Commissioner, No. 16-70496 (9th Cir. 2018). The issue before the Ninth Circuit was the validity of transfer pricing regulations that require related companies to allocate expenses that unrelated parties do not share when dealing at arm’s length.» Read More
The below post is written by guest author Elena Bassan, an attorney with the Italian law firm Studio Bassan.
Today, we comment on a ruling of the Supreme Court of Cassazione (no. 3692 of 15 February 2018) concerning a product reported to be allegedly defective due to its content of heavy metals (nickel).» Read More