In Mendu v. United States, the Court of Federal Claims held that penalties for failure to timely file a Report of Foreign Bank and Financial Accounts (FBAR), commonly known as “FBAR penalties,” were not subject to the Flora full payment rule, which requires a plaintiff to make payment of the full tax amount before they bring suit in the Court of Federal Claims or any US district court for the refund of any “internal-revenue tax.”
This week’s Government Enforcement video discussion, led by Baker McKenzie’s Tom Firestone and Jerome Tomas, will cover topics such as the Russian response to US sanctions, the trial of Mayor of Fall River, Massachusetts for extorting marijuana businesses, SEC Commissioner Peirce’s statement on an Index Fund SEC settlement, and the SEC and cyrpto assests.
On 26 March 2021 Saudi Arabia’s long awaited Privatisation Law was published, promulgated by Council of Ministers’ Resolution No. 436 dated 3/8/1442H (corresponding to 16 March 2021) and Royal Decree M/63 dated 5/8/1442H (corresponding to 18 March 2021) (the “Privatisation Law”). The Privatisation Law will come into effect 120 days after publication, and will provide a transparent and flexible regulatory framework for the procurement and documentation of Public Private Partnership projects (“PPPs”) and existing asset privatisations (“Asset Privatisations”) in the Kingdom (“Privatisation Projects”).
Canada’s Federal Budget 2021 (“Budget 2021”) proposes to expand the disclosure rules for certain transactions, which is in line with the measures recommended in the OECD’s Base Erosion and Profit Shifting Project, Action 12: Final Report (BEPS Action 12 Report).
The proposed expansion of mandatory disclosure rules contemplates: (i) changes to the Income Tax Act’s (ITA) existing reportable transaction rules; (ii) a new requirement to report notifiable transactions; (iii) a new requirement for specified corporations to report uncertain tax treatments; and (iv) an extension of the reassessment period in respect of transactions that are subject to the new disclosure rules and addition of penalties for failure to comply.
With a Report published on 21 April 2021, the Italian Medicines Agency (AIFA) made available the preliminary data relating to the Monitoring of the National and Regional Pharmaceutical Expenditure for the year 2020.
This week’s discussion covers crypto developments including SEC Chair Gensler’s Testimony, Dogecoin and Saturday Night Live. Our team also discusses “Swiss George Floyd Case”.
The Multistate Tax Commission (MTC) is set to revamp its transfer pricing collaboration and enforcement initiatives following the first public meeting of its State Intercompany Transactions Advisory Service (SITAS) Committee in over four years.
We invite you to join us on Friday, 21 May 2021, as we take a closer look at the future of disputes in Asia Pacific. Our 90-minute webinar features a panel discussion on the “Digital Transformation of Disputes”.
In the latest edition of our Labor and Employment video chat series for US employers William Dugan, Krissy Katzenstein and Aleesha Fowler discuss key considerations for employers involved in high profile investigations
Episode 12: Singapore – MAS Revises Technology Risk Management Guidelines The Monetary Authority of Singapore (MAS) recently revised its Technology Risk Management Guidelines 2021 after feedback from a 2019 public consultation and engaging with cyber security experts. In this episode, Stephanie Magnus, Ken Chia, and Ying Yi Liew take a closer look at compliance, regulator expectations, cyber threats, and other important considerations — taking into account that financial institutions encompass large multinational banks, insurance companies and small fintech startups.