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Denmark targets investors tied to Sanjay Shah at US tax fraud trial

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Weeks after Danish judges sentenced hedge fund trader Sanjay Shah to 12 years in prison, the country’s lawyers turned to a U.S. court in a bid to recoup about $500 million lost in the Cum-Ex tax dividend scandal.

Lawyers for the Nordic country told a New York jury that a group of US investors helped Shah steal from the Danish treasury by filing 1,200 fraudulent requests for tax rebates on dividends.

“This case is about greed and theft,” Marc A. Weinstein, a lawyer for the Danish tax authority, said during opening statements at a civil trial that started this week in federal court in New York. “They lined their own pockets, the pockets of their friends and families and the pockets of their coconspirators with the funds they stole from Denmark.”

Shah, who was sentenced to prison last month for orchestrating a scheme that netted 9 billion kroner ($1.24 billion) through thousands of sham dividend tax refund applications, has become the public face of the Cum-Ex tax scandal that has engulfed bankers and lawyers in several European countries. Three people have been convicted of Cum-Ex related crimes in Denmark, and about 20 in Germany.

Cum-Ex was a controversial trading strategy designed to obtain duplicate refunds by taking advantage of how dividend taxes were collected and regulated a decade ago. Germany is looking at about 1,800 suspects from across the global financial industry in probes linked to the practice.

Denmark’s Customs and Tax Administration, also known as SKAT, has been pursuing traders and businesses around the world in a bid to claw back the billions it says it lost through trading schemes spearheaded by Shah. The case is the first to go to trial in the U.S. over Cum-Ex fraud linked to the hedge fund founder.

But a lawyer for two of the investors, Richard Markowitz, and his wife, Jocelyn Markowitz, told the jury that SKAT allowed Cum-Ex transactions to flourish for years before trying to stop the practice. He compared the tax agency to the town officials in the movie Jaws who were so focused on the tourist trade that they “didn’t do anything until the bodies started piling up.”

“Rich and Jocelyn did not do anything wrong. They didn’t lie, they didn’t cheat,” said Peter Neiman, a lawyer for the couple, during his opening arguments. “SKAT was not careful.” 

Shah was a suspect in probes in both Denmark and Germany. German prosecutors also accused him of routing Cum-Ex deals through the U.S., saying in one indictment that he used a Jewish school in Queens to execute trades totaling €920 million euros ($948 million) as part of a plan to deceive tax authorities.

Shah, the founder of Solo Capital, became the most prominent figure of the Cum-Ex scandal after a 2020 Bloomberg TV interview where he said that “bankers don’t have morals” and expressed no remorse for taking advantage of what he said were loopholes in some countries’ tax codes.

Denmark says that Richard Markowitz, John van Merkensteijn and two of their partners at a New York financial services firm, Argre Management, were recruited by Shah to take part in the scheme in 2012. Pension plans created by Argre became customers of Shah’s hedge fund, which served as the purported custodian of Argre’s Danish shares, and issued fraudulent statements for a rebate on dividend taxes that were withheld.

The plans, including ones established by their wives, Jocelyn Markowitz and Elizabeth van Merkensteijn, later submitted those statements as proof that the company was entitled to the refunds, the Danish tax agency says.

SKAT has sued approximately 260 pension plans and individuals in the U.S. over Cum-Ex. The country has also filed civil cases seeking to claw back Cum-Ex funds in other countries. A trial in London wrapped up last month where SKAT is suing dozens of traders and businesses. 

If Neiman agreed with the Danish tax agency on anything, it was that Shah was the real villain. He said that Markowitz and Van Merkensteijn, “honestly and in good faith” entered into what they believed were legitimate dividend arbitrage transactions, first in Germany, later in Belgium and then in Denmark, only to find out that Shah had deceived them.

“It was only years later that they found out that Sanjay Shah had at some point stopped doing what he had promised and had begun to lie to them over and over and over again,” he said.

“The blame here lies with Sanjay Shah and Solo,” said Sharon McCarthy, a lawyer for the van Merkensteijns.

The case is In Re: Customs and Tax Administration of the Kingdom of Denmark (Skatteforvaltningen) Tax Refund Scheme Litigation, 18-md-2865, U.S. District Court, Southern District of New York. 

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Accounting

Continuous Auditing Transforms Corporate ERPs

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continuous auditing transforms corporate erps

As corporate accounting departments cross the threshold into late July 2026, the adoption of continuous, automated auditing systems has reached a definitive turning point. Driven by advances in artificial intelligence and deep integration with modern Enterprise Resource Planning (ERP) platforms, leading finance organizations are moving away from traditional, periodic post-hoc audits in favor of real-time, 100% transactional verification. This technological transition is redefining internal control environments, reducing compliance costs, and eliminating the structural delays inherent in legacy quarterly closing processes.

Unlike traditional auditing frameworks that rely on statistical sampling—a process that inevitably leaves operational blind spots—continuous auditing software monitors operational data feeds continuously. Every purchase order, electronic invoice, payroll disbursement, and cross-border wire transfer is automatically cross-referenced against established corporate governance parameters, regulatory tax schedules, and anti-fraud algorithms in real time. Anomalies or unauthorized ledger entries are flagged instantly, allowing internal audit teams to investigate and remediate compliance gaps immediately rather than months after the close of a financial period.

The implications for executive financial management are far-reaching. By embedding continuous verification directly into daily transaction workflows, chief financial officers gain uninterrupted visibility into the organization’s true financial standing. Real-time balance sheet auditing eliminates the severe operational bottlenecks associated with month-end and quarter-end financial reconciliations, freeing accounting professionals to focus on strategic financial modeling, tax planning, and capital allocation rather than manual data entry and spreadsheet consolidation.

However, implementing continuous auditing requires accounting leadership to invest heavily in data governance and technical upskilling. Internal audit teams must evolve from manual ledger reviewers into system architects capable of auditing complex algorithms and validating automated data pipelines. Accounting firms and corporate controllers that master continuous auditing will establish a resilient compliance framework capable of meeting stringent international regulatory standards with total transparency.

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Accounting

U.S. Imposes New 50% Tariffs on Canadian Imports Under Rare Legal Provision

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U.S. Imposes New 50% Tariffs on Canadian Imports Under Rare Legal Provision

WASHINGTON — In a major escalation of cross-border trade friction, U.S. President Donald Trump has signed executive orders imposing new 50% tariffs on a wide selection of Canadian exports, citing discriminatory practices by Ottawa targeting American auto, dairy, and beverage industries.

The new duties, announced Monday, will take effect in 30 days. They target a broad spectrum of consumer and industrial goods—ranging from wine, liquor, and milk products to commercial cement, furniture, clothing, and hockey equipment.

Untested Legal Mechanism

To enact the sweeping measures, the administration invoked Section 338 of the Tariff Act of 1930—a rarely used legal provision allowing the executive branch to levy additional tariffs of up to 50% on foreign nations deemed to discriminate against U.S. commerce.

White House officials noted that Section 338 addresses trade discrimination rather than national security or economic emergencies. The move comes months after prior global emergency tariffs faced legal challenges in domestic courts, signaling Washington’s pivot toward alternate statutory authorities to maintain import duties.

Senior administration officials briefed reporters that the measure directly responds to Canadian provincial bans on U.S. alcohol, restrictions on American vehicle exports, and import quota disparities affecting U.S. dairy and cheese producers relative to third-party trading partners.

“While the administration continues to secure reciprocal trade agreements globally, Canada retaliated against efforts to protect domestic industry,” U.S. Trade Representative Jamieson Greer stated.

USMCA Impact and Carve-Outs

Significantly, the newly ordered 50% duties will apply to designated items even if they otherwise comply with the United States-Mexico-Canada Agreement (USMCA).

However, the administration confirmed key targeted exemptions:

  • Energy products (including oil and natural gas)
  • Potash and critical minerals
  • Fish and seafood
  • Goods already governed by sector-specific duties (such as existing steel and aluminum tariffs)

Administration representatives emphasized that the tariffs do not stem from recent disputes concerning drifting Canadian wildfire smoke, noting that policy options regarding environmental spillover remain under separate review.

Canadian Response and Market Reaction

Following the White House announcement, the Canadian dollar experienced a sharp decline against the U.S. dollar, falling approximately 0.4% during evening trading.

Canadian Prime Minister Mark Carney issued a statement emphasizing that Canada’s earlier counter-duties had merely matched previous U.S. trade actions. “Canada stands ready to engage intensively to address outstanding issues with the U.S. to the mutual benefit of our citizens,” Carney stated, pointing to detailed proposals Ottawa submitted to modernize the USMCA framework.

Ontario Premier Doug Ford took a firmer stance, urging a “dollar-for-dollar” reciprocal response if the measures go into effect on August 19.

With a 30-day implementation window before the duties officially lock in, industry associations and trade groups on both sides of the border are calling for urgent bilateral negotiations to avert further supply chain disruption across North America.

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Accounting

Automated Continuous Auditing: Transforming Compliance and Real-Time Financial Oversight

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Transforming Compliance and Real-Time Financial Oversight

The traditional accounting paradigm—defined by periodic monthly closures and post-hoc annual audits—is rapidly giving way to continuous, automated financial oversight. As of July 2026, forward-thinking accounting practices and multinational corporate finance departments are leveraging continuous auditing systems powered by advanced machine learning models. These systems monitor operational transactions in real time, shifting audit methodologies from sample-based post-analysis to absolute, 100% transaction-level verification.

The operational advantages of continuous auditing are transformative. Standard auditing procedures historically relied on statistical sampling, which, despite rigorous methodology, inherently left gaps where anomalies or fraudulent transactions could go undetected for months. Modern continuous auditing platforms integrate directly with enterprise resource planning (ERP) databases, instantly cross-referencing purchase orders, invoices, bank feeds, and tax records. Any deviation from established control parameters or unusual transaction behavior triggers immediate flags for internal audit teams, dramatically reducing detection lag from quarters to seconds.

Beyond fraud prevention, continuous auditing fundamentally alters internal reporting and decision-making. Executive leadership no longer has to wait weeks after the close of a quarter to evaluate precise financial standing; real-time verified ledger data provides an uninterrupted view of operating margins, tax liabilities, and cash flow dynamics. This real-time visibility enables corporate controllers to adjust capital allocation strategies dynamically, mitigating liquidity constraints and capitalizing on emerging commercial opportunities far more efficiently than competitors bound to legacy reporting cycles.

However, implementing continuous auditing requires accounting professionals to acquire new analytical capabilities. The role of the auditor is evolving from manual data reconciliation toward system validation, algorithmic model governance, and strategic risk interpretation. Accounting firms and corporate finance departments must invest in continuous technical education, ensuring that audit staff possess the data engineering skills necessary to design, maintain, and evaluate complex automated compliance systems.

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