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A Glimmer of Hope for Lower Criminal and Civil FBAR Penalties
The year 2010 will go down in history as the year the great wall of Swiss bank secrecy officially collapsed. On June 17, 2010, the Swiss Parliament ratified the settlement agreement between the U.S. Department of Justice (DOJ) and UBS AG, and the process of turning over the names and Swiss banking information of approximately 4,450 U.S. taxpayers began. For taxpayers who missed the opportunity to participate in the Internal Revenue Service's special Off-shore Voluntary Disclosure Program (OVDP), which ended in October 2009, the chance of criminal prosecution is high.
This article addresses the potential penalties facing taxpayers with undisclosed foreign accounts and focuses in particular on the draconian penalties being issued across the board for failure to file Form TDF 90-22.1, Report of Foreign Bank and Financial Accounts ' commonly referred to as an “FBAR.” And we also discuss a recent decision out of the Eastern District of Virginia, which provides some small hope that the government will begin to exhibit a bit of flexibility in its approach to FBAR penalties.
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New York's Latest Cybersecurity Commitment
On Aug. 9, 2023, Gov. Kathy Hochul introduced New York's inaugural comprehensive cybersecurity strategy. In sum, the plan aims to update government networks, bolster county-level digital defenses, and regulate critical infrastructure.
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Bit Parts
Summary Judgment Denied Defendant in Declaratory Action by Producer of To Kill a Mockingbird Broadway Play Seeking Amateur Theatrical Rights
How AI Has Affected PR
When we consider how the use of AI affects legal PR and communications, we have to look at it as an industrywide global phenomenon. A recent online conference provided an overview of the latest AI trends in public relations, and specifically, the impact of AI on communications. Here are some of the key points and takeaways from several of the speakers, who provided current best practices, tips, concerns and case studies.