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The Rise of International Tax Enforcement and the Increasing Convergence Among Tax, Criminal, Money Laundering, and Evidence Gathering



Friday, April 20, 2012
Product Code - TMA90
Speaker(s): Bruce Zagaris, Berliner, Corcoran & Rowe, LLP and Alan Granwell DLA Piper
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 During the last few years international tax enforcement has increased in the U.S. and globally. In the United States, the Internal Revenue Service and the Department of Justice are continuing an aggressive campaign to investigate and prosecute offshore tax evasion. Internationally, developed and developing countries are aggressively investigating and prosecuting offshore tax evasion and enacting legislation to curb such activity.

What these developments mean and what the implications are for practitioners, taxpayers, governments, and other stakeholders, is the subject of this webinar.

During this webinar the presenters will cover:

  • The IRS’ third offshore voluntary disclosure program.
  • The Treasury Department’s newly-proposed FATCA regulations
  • Congressional consideration of additional anti-tax haven legislation
  • Initiatives of the G20 and the OECD – and the proliferation of bilateral and multilateral tax exchange agreements
  • The continuing discussions between Switzerland and the United States as to how to resolve the ongoing investigations of Swiss financial institutions
  • Intergovernental approaches between the US, the EU, and beyond

Educational Objectives

  • Know how to anticipate and avoid new legal and ethical traps for clients and service providers
  • Understand the full weight and impact of current bilateral and multilateral tax agreements on you and your client
  • See how FATCA proposed regulations will impact financial institutions, tax planners, wealth managers, and the clients
  • Assess next steps as Congress considers additional action on anti-tax havens

Bruce Zagaris, Berliner, Corcoran & Rowe, LLP and Alan Granwell DLA Piper

 Bruce Zagaris, a Partner with the firm of Berliner, Corcoran & Rowe, LLP, in Washington, DC, has served as counsel in more than forty criminal trials and approximately five appellate cases. In addition, he has handled evidence gathering and extradition cases both on the interstate and international levels and cases involving prisoner transfer applications. His criminal work has included counseling on extradition and international evidence gathering cases, testifying as an expert in international criminal cases involving money laundering and tax crimes, counseling of witnesses for grand jury investigations, prisoner rights, representation of parolees, probation revocation matters, and early release of prisoners on emergency medical problems.

His private practice has also included monitoring international tax and enforcement developments in the U.S. and the Caribbean for foreign governments and corporate clients.

Mr. Zagaris earned a B.A., J.D., and LL.M. from The George Washington University. His B.A. included a major in international affairs with a specialty in Latin American Affairs. After serving as a law clerk for the U.S. District Court for the Southern District of West Virginia (1972-73), Mr. Zagaris was an Assistant Attorney General for the State of Idaho (1973-74). Mr. Zagaris received graduate legal diplomas from Stockholm University, Sweden (1975) and from the Free University, Brussels (1976). While in Scandinavia, Mr. Zagaris did research as a result of Swedish and Finnish government sponsored scholarships.

During his two years in Europe, in 1974-76, Mr. Zagaris worked for the Nordic Law Consultants and served as a UN consultant to the Mano River Union, a customs union in West Africa. At the Free University's Program on International Legal Cooperation (PILC), Mr. Zagaris took international criminal law from Bart deSchutter. In 1976-77, Mr. Zagaris was in private practice with Glad, Tuttle & White in San Francisco. In 1977-78, he was a lecturer at the Faculty of Law, University of the West Indies, Barbados, teaching comparative law, public international law, and international tax law.

Mr. Zagaris was an Adjunct Professor for six years at the Washington College of Law, American University in Washington, and at the Fordham University Law School in New York, where he taught international business criminal law. He has also been an Adjunct Professor at John Marshall College in Chicago and the University of Montana School of Law.

Alan Winston Granwell is a member of the international tax department of DLA Piper, resident in Washington, DC. Mr. Granwell’s practice encompasses representing multinational corporations and high net worth individuals on cross-border tax planning. Mr.Granwell advises financial institutions and their clients on international tax enforcement initiatives, including FATCA. He also conducts an active administrative practice, regularly representing clients before the Internal Revenue Service and the US Treasury Department.

From 1981 through 1984, Mr. Granwell was the International Tax Counsel and Director, Office of International Tax Affairs at the US Department of the Treasury. In that capacity, Mr. Granwell was the senior international tax advisor at the Treasury Department and was responsible for advising the Assistant Secretary for Tax Policy on legislation, regulations, and administrative matters involving international taxation and directing the US tax treaty program.