IRS Announces 2011 Offshore Voluntary Disclosure Initiative

This week the U.S. government announced a new offshore voluntary disclosure initiative (“2011 OVDI”). Under this 2011 OVDI, taxpayers who voluntarily come forward and report their previously undisclosed foreign accounts and assets by August 31, 2011 will be excused from criminal prosecution. Will the 2011 OVDI Succeed? IRS Commissioner Shulman said in announcing the 2011 […]

India May Be Focus of IRS Foreign Account Investigations

Media reports in 2010 indicated that the Justice Department may be using data from India as a basis for opening investigations of U.S. taxpayers with suspected unreported offshore accounts at HSBC in India, Singapore, and Hong Kong.  Last month, Rick Raven, the IRS Deputy Chief for Criminal Investigations, reported that IRS Criminal Investigations Chief Victor […]

Does Your Bank Need Representation in Tallahassee?

Gunster has recently expanded its Tallahassee office, which is now home to the firm’s Government Affairs practice.  This 12-person team has a deep proficiency in government relations and navigates  all levels of state government-Executive, Administrative, Legislative and Regulatory.  Their experiences and relationships, as well as their presence in Tallahassee, make our government affairs team uniquely […]

FinCEN Issues Guidance Regarding Recent Events in Tunisia

On January 14, 2011, a wave of social protests ended Tunisian president’s Zine El Abidine Ben Ali (“Ben Ali”) 23-year old regime.  Ben Ali reportedly fled Tunisia for Saudi Arabia and is estimated to have amassed a fortune in excess of $5 billion as a result of the misappropriation of state assets and public corruption. […]

New Rules on Interest Reporting for Nonresident Aliens Proposed

Earlier today (January 6, 2011), the Internal Revenue Service issued new proposed regulations which, if finalized, will require annual reporting of interest paid on deposits maintained by nonresident aliens at U.S. offices of certain financial institutions.  These new proposed regulations replace ones that were issued in August 2002 (the “2002 Proposed Regs”), which themselves replaced […]

OFAC Issues Final Rule to Amend the Cuban Asset Control Regulations

Yesterday, the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued a final rule (“Final Rule”) amending the Cuban Assets Control Regulations (31 CFR Part 515) (“Cuba Regulations”) to implement policy changes announced by President Obama on January 14, 2011, designed to increase people-to-people contact, support civil society in Cuba, enhance the free flow […]

USCIS Reaches FY 2011 H-1B Cap

On January 27, 2011, U.S. Citizenship and Immigration Services (“USCIS”) announced that it had reached the number of the statutory cap of H-1B Petitions for fiscal year (“FY 2011″) on January 26, 2011. Consequently, January 26, 2011 is the final receipt date for new H-1B specialty occupation petitions requesting an employment start date in FY […]

Required Use of E-Verify by Florida Contractors

Whether you are an in-state or out-of-state employer who contracts with Florida state agencies, or have been merely following the recent trend of states asserting themselves into the Immigration Reform Debate in the absence of Federal Comprehensive Immigration Reform, it is important to note that immediately after being sworn-in as Florida’s 45th Governor, Rick Scott, issued Executive […]

FinCEN Issues Advisory: Risks with Jurisdictions Identified by FATF as Having Strategic Deficiencies in Their AML/CTF Regimes

On November 18, 2010, the Financial CrimesEnforcement Network (“FinCEN”), issued an advisory(“Advisory”) to inform banks and other financialinstitutions operating in the United States of the risksassociated with jurisdictions identified by the FinancialAction Task Force (“FATF”) on October 22, 2010(“Public Statement”), as having strategic deficienciesin their anti-money laudenring (“AML”) and counterterroristfinancing (“CFT”) regimes. In the Public […]


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