New U.S. Tax Enforcement Efforts: Offshore Banking and Data Privacy

James N. Mastracchio, Partner, Eversheds Sutherland

Venue : AmCham Office, 1 Scotts Rd, Shaw Centre #23-03 S(228208) - Stamford American Auditorium

Date : October 18, 2018

Time : 8:00 AM - 9:30 AM

Price : $0.00

2018-10-18 08:00:00 2018-10-18 09:30:00 Asia/Singapore New U.S. Tax Enforcement Efforts: Offshore Banking and Data Privacy - AmCham Office, 1 Scotts Rd, Shaw Centre #23-03 S(228208) - Stamford American Auditorium AmCham Singapore Register for event

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Hosted by the Financial Services and Legal & IPR Committees


8:00 am – 8:15 am
      Registration & Networking
8:15 am – 8:20 am      Introduction
8:20 am – 9:00 am      Presentation
9:00 am – 9:25 am      Q&A / Discussion
9:25 am – 9:30 am      Closing


The U.S. taxing authorities have adopted new initiatives focused on the Singapore banking and financial industry.

(1) The U.S. Congress recently appropriate funds to tax enforcement agencies to investigate whether financial institutions, trust companies, and securities companies located in Singapore have enabled U.S. account holders to avoid U.S. income tax and informational reporting.
  This is a new initiative stemming from information gathered from the DOJ Swiss Bank Program and involves multiple U.S agencies.  While investigations in other parts of the world have been underway for some time, new tools and methods have been developed by investigatory agencies and these new tools will be discussed.

  The U.S. Congress has enacted legislation that allows the U.S. authorities to gain access to electronically stored data anywhere in the world.  This new law sets aside court cases that limited such access based on pre-existing data privacy rules. The contours of the new law and how it will impact your businesses will be explained.

About the Speakers

James N. Mastracchio
Eversheds Sutherland

With more than 30 years of tax experience, Jim Mastracchio advises domestic and multinational clients on a variety of federal tax controversy matters, with an emphasis on complex civil and criminal tax disputes, and litigation.

Civil Tax Representations
Jim regularly represents clients in all phases of federal tax controversies, including examination and administrative appeals. Jim has also represented clients before the US Tax Court and US District Courts. His extensive experience includes debt versus equity, valuation disputes, accounting methods, tax shelters, structured tax products, insurance, informational return penalties, fraud penalties and other substantive tax issues.

Criminal Tax Representations
Jim is routinely retained for criminal tax matters. These cases range from handling administrative investigations to complex grand jury investigations involving tax and related crimes. Jim’s clients include corporations, board members and senior management, professional service firms, and individual clients facing criminal tax investigations and prosecution. Jim has handled many large criminal tax matters, including acting as an Independent Examiner in the Department of Justice’s Swiss Bank Program and serving as lead counsel in the criminal tax prosecution of a financial institution and its subsidiaries located in the Cayman Islands.

Offshore Advice and Defense
Since 2009, more than 450 clients have sought Jim’s advice regarding the various IRS Offshore Voluntary Disclosure Programs, addressing a variety of tax compliance issues. In addition to ensuring that the complexities of these programs are satisfied, Jim advises on proper informational return reporting, including compliance with Report of Foreign Bank and Financial Accounts (FBARs) reporting, foreign gift and trust reporting (Form 3520), foreign corporation and partnership reporting (Forms 5471 and 8865), and tax and informational reporting for international asset holding structures.

Over the past year, Jim has been retained by a number of clients facing willful FBAR penalties arising from undisclosed foreign accounts. He is handling FBAR cases pending before the IRS, the Department of Justice Tax Division and in US District Courts. These matters involve some of the first cases to ever be initiated by the US government regarding non-compliant informational return reporting by US persons.