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21 June 2007 / Gary Summers , Mark Howard , Susan Bradshaw
Issue: 7278 / Categories: Features , Tax
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The ticking time bomb (2)

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The ever-changing HMRC landscape requires increased vigilance from financial professionals, say Gary Summers, Mark Howard and Susan Bradshaw

Contemporary UK law enforcement strategies—referred to in the first article of this two-part series (see NLJ, 11 May 2007, pp 660–61)—appear to have been based on previous initiatives by the Internal Revenue Service in the US. This is yet another example of the extra-territorial ambit of US statutory regulation since 9/11 which is fast becoming all-pervading.

Pasquantino

In the offshore arena, the decision of the US Supreme Court in Pasquantino v US (2005) 125 S Ct 1766 that a scheme to defraud a foreign government of tax revenue violates the US wire fraud statute providing there is a US link—despite the revenue rule, a common law doctrine prohibiting US courts from enforcing a foreign state’s domestic tax infrastructure—is highly significant. Such a link could be established if the transaction was in US dollars. Frequent worldwide travellers will appreciate the ambit of this decision, which makes the prosecution of a foreign

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