United States Tax Investigations - Current Risks, Future Challenges, and Potential Opportunities
The US Internal Revenue Service and the US Department of Justice have demonstrated that they can alter the landscape for private client banking. Recent US tax enforcement efforts have imposed expensive and business-changing investigations on institutions, and have given rise to aggressive prosecutions in the US of non-US individuals. The pace of US government activity is accelerating and is likely to impact increasing numbers of banks, fiduciaries, relationship managers, and individual clients.
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The presentation will address issues that banks, fiduciaries, and individuals must consider in light of US efforts to reach beyond US borders. The presenters will address how to respond to US government inquiries, procedures in US investigations, and the application of US law outside the United States. Perhaps most importantly, the presenters will provide options for assessing exposure to US civil and criminal penalties, and they will describe how institutions and individuals can determine whether and how to affirmatively engage US authorities to resolve exposures before an investigation begins.
Baker & McKenzie Geneva
Rue Pedro-Meylan 5
Tel: +41 (0)22 707 9800
Fax: +41 (0)22 707 9801