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Overseas Financial Accounts: The Rules are in Flux and Financial Intermediaries and Clients are Increasingly Targets


Monday, April 20, 2009
Product Code - TMAU02
Speaker(s): Bruce Zagaris, Michael Shepard
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Agenda

The program reviews unilateral U.S. enforcement efforts against overseas bank accounts, administrative and regulatory changes, diplomatic efforts and actions by international organizations, and proposed legislative initiatives to tackle the problem of taxpayers using offshore accounts to evade taxes.

Presentation Objectives:
The objectives of this 60-90 minute webinar, recorded on April 20, 2009, include providing participants with a conceptual understanding and practical application of the following:
I. Recent Unilateral Enforcement Efforts Against Foreign Bank Accounts
The UBS Investigations and Prosecutions; The Permanent Subcommittee on Investigations; Initiatives in Other Countries
II. New Foreign Bank Account Report
III. The Status of Voluntary Disclosure Arrangements
IV. The International Organization and Related Initiatives:  The OECD Harmful Tax Practices Initiative; The Recent Pledges by Tax Havens to Comply; The G20 Meeting on the Global Financial Crisis; EU Initiatives
V. Proposed U.S. Legislative Initiatives
The Stop Tax Haven Abuse Act; The Baucus Alternative; Making Foreign Tax Crimes a Money Laundering Offense (subsec. 2(g) of the Fraud Enforcement and Recovery Act of 2009) (S. 386); Possible effects on Banks' AML Monitoring Programs
VI. Analysis and the Way Forward

Upon completion of this program, participants will be able to:

• Understand the latest developments in the U.S. investigations against UBS and U.S. taxpayers with undeclared foreign bank accounts
• Understand the potential resolution of the U.S. investigations against UBS and U.S. taxpayers with undeclared foreign bank accounts
• Identify the trends and pressures facing financial intermediaries and fiduciaries and recognize the prospective changes in their work
• Recognize and understand implications of pending international initiatives to provide anti-tax haven legislation
• Recognize proposed U.S anti-tax haven legislative initiatives 

Speakers

Bruce Zagaris, Michael Shepard

Michael Shepard
Michael Shepard is a Principal in Deloitte Financial Advisory Services LLP concentrating on anti-money laundering, Bank Secrecy Act, and OFAC compliance consulting for financial institutions. Previously, Michael was the head of the BSA/AML program and Deputy General Counsel at Commerce Bancorp. He was as a partner at Blank Rome LLP, a major regional law firm where he practiced for 14 years. His practice focused on white collar criminal defense and AML regulatory compliance matters. In 1987, he began his law career at the U.S. Department of Justice, Tax Division, Criminal Section.

Bruce Zagaris
Bruce Zagaris is a partner in the Washington, D.C. firm of Berliner Corcoran & Rowe. His practice includes structuring international business transactions and especially international tax aspects. Bruce has counseled persons in international estate planning, including officials working with international organizations.

His practice has focused on advising attorneys and clients on regulatory and compliance aspects of transactions. He has counseled individuals under audit, including some involving the promotion of tax shelters.

Mr. Zagaris has regularly advised foreign governments including Barbados and Belize, and has worked with the UN Group of Ad Hoc Experts on International Tax Matters. At the request of the House Ways & Means oversight Subcommittee, Mr. Zagaris testified on the tax information exchange agreements under the Caribbean Basin Economic Recovery Act. At the request of the Subcommittee on Commerce, Consumer and Monetary Affairs, Committee on Government operations, he testified on the state of the U.S. Government's efforts to combat international tax evasion,

Mr. Zagaris was co-chair of International Exchange of Tax Information Recent Developments and is a frequent speaker at international tax and financial law programs. A prolific writer, Bruce has authored more than 100 articles on international tax law.