Section 5000C Tax Raises Withholding Issues For Banks

Since 2011, Section 5000C of the U.S. Internal Revenue Code has imposed an IRS-administered withholding tax on billions of dollars of products and services sold annually by foreign vendors to U.S. federal government agencies. One of the many issues raised by Section 5000C is the possibility that foreign and U.S. banks in the chain of […]


Proposed E-Verify Legislation Filed in both the Florida House and Senate

State Representative Gayle Harrell (District 81- Port St. Lucie) and State Senator Thad Altman (District 24 – Melbourne) have filed companion legislative bills, HB1315 and SB 1638, respectively, with provisions relating to the verification of employment eligibility by employers in Florida, including mandatory use of the federal government’s E-Verify system. Both of the bills have […]


IRS Announces 2012 Offshore Voluntary Disclosure Program

Commissioner Schulman cautions that “. . . people need to come in and get right with us before we find you.” This month the U.S. government announced its third offshore voluntary disclosure program (“2012 OVDP”). Under this 2012 OVDP, taxpayers who voluntarily come forward and report their previously undisclosed foreign accounts and income will be […]


Treasury Designates Bank Tejarat For Its Involvement In WMD Proliferation Activities

The U.S. Department of Treasury (“Treasury”) recently announced (“Announcement”) the designation of Iran’s third-largest bank, Bank Tejarat, under Executive Order 13382 – Blocking Property of Weapons of Mass Destruction (“WMD”) Proliferators and Their Supporters. Treasury designated Bank Tejarat after finding that Bank Tejarat provided financial services to: (i) Bank Mellat; (ii) the Export Development Bank […]


OFAC Issues Regulations Relating to Transnational Criminal Organizations

The Office of Foreign Assets Control (“OFAC”) has recently issued the Transnational Criminal Organizations Sanctions Regulations (“TCO Regulations”) to implement Executive Order 13581 of July 24, 2011, Blocking Property of Transnational Criminal Organizations (“Executive Order”).FinCEN will continue to accept submissions to its Bank Secrecy Act E-Filing System that use the most current “legacy” forms (i.e., […]


The 2012 Essentials Seminar hosted by the Society of Corporate Secretaries & Governance Professionals

The 2012 Essentials Seminar hosted by the Society of Corporate Secretaries & Governance Professionals is approaching and, we are pleased to announce that Gunster Shareholder David Scileppi will be speaking on a panel during the three-day program. The seminar will cover fundamentals of corporate governance and the role of the corporate secretarial function for those working […]


12th Annual FIBA Anti Money Laundering Compliance Conference

Dear Friends, We are approaching our 12h Annual FIBA AML Compliance Conference, to be held on February 23-24, 2012. The Conference will focus on recent BSA/AML/OFAC developments and topics, including, among others: • What’s New in the AML Landscape • OFAC & Implementing Iran Sanctions under CISADA; • Banks, Subpoenas and Writs – What’s the Right Response? • SAR […]


New Cybersecurity Disclosure Obligations for SEC Filings

Risks of Cyber Attacks If you are an executive for a public company, new SEC guidance requires you to consider cybersecurity in your ongoing periodic reports.  As evidenced by the barrage of news reports over the past couple of years, cyber incidents have become very significant events for all types of companies.  A recent example […]


Record Demand for U.S. Visas from Brazilian and Chinese Nationals

The U.S. Department of State (DOS) reported on December 21, 2011, that its U.S. Mission to Brazil processed a record 820,000 U.S. visa applications in fiscal year 2011, a 42 percent increase from the previous fiscal year. The demand for U.S. visas in China also increased at an unprecedented rate.  U.S. consular officers in China […]


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