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Guindon: SCC Hears Arguments in Penalty Case

The Supreme Court of Canada heard oral arguments today in the case of Guindon v. The Queen (Docket No. 35519). At issue in the case is the nature of the third-party penalty in section 163.2 of the Income Tax Act....more

IRS and DOJ Crack Down on Cash Reporting Violations

Federal law requires that anyone engaged in a trade or business who receives more than $10,000 in U.S. currency is required to file a Form 8300 (available here) with the Internal Revenue Service. Failure to do so can subject...more

Corporate Liability: The Italian Supreme Court Extends The Scope Of Application Of Legislative Decree N. 231/2001

The Italian Supreme Court has reconsidered the possibility of applying Legislative Decree No. 231/2001 (the “Decree”) not only to the offence of conspiracy, but also to the so-called target offences of a criminal organisation...more

Focus on Tax Controversy and Litigation - July 2014

In this issue: - Supreme Court Limits Taxpayer’s Ability to Examine the IRS at a Summons Enforcement Hearing - Court Determines Tax Analysis not Protected by Attorney-Client Privilege and Work Product Doctrine...more

Can an OVDP Participant Set Aside a Closing Agreement on the Theory of Duress?

It has been just over five years since the Internal Revenue Service (“IRS”) offered the first of three offshore voluntary disclosure programs for individuals with undisclosed foreign financial accounts. Since the announcement...more

On The Chopping Block: Banks And Financial Institutions

The Department of Justice has had enough. Banks and other financial institutions are not just on the radar screen – they are on the chopping block. One-by-one watch out – banks and other financial institutions are coming...more

Court’s Ruling Holding Corporate Officer Responsible for Trust Fund Recovery Penalty Illustrates Risk of Personal Liability for...

A district court in the Northern District of California has held that the officer of a now-defunct corporation is personally responsible for the Trust Fund Recovery Penalty based upon the company’s failure to collect, account...more

BankinBits First Quarter Recap

The BankinBits blog, which discusses recent developments in the banking industry, has within the first quarter of 2014 addressed a diverse range of topics including banking services for the marijuana industry, the shuttering...more

Battuta D'arresto Per La Voluntary Disclosure

Come annunciato, l'articolo 1 del decreto legge 28 gennaio 2014, n. 4 (pubblicato in G.U. n. 23 del 29 gennaio 2014 – di seguito "Decreto") in materia di "Voluntary Disclosure" o "Collaborazione Volontaria" per il rientro dei...more

Marijuana Taxation Update: State Sanctioned Marijuana Industry Must Keep the Federal Anti-Drug Trafficking Tax Code in Mind

As we have previously reported, despite the growing number of States that have authorized the use of marijuana in various forms, the federal government has continued to crack down on dispensaries. In addition to direct...more

A Rose by any Other Name: DOJ’s FCPA Unit Brings Fraud and Money Laundering Charges Against Bechtel Executive

The variety of charges recently brought by the US Department of Justice’s (DOJ) Foreign Corrupt Practices Act (FCPA) Unit against former Bechtel executive Asem Elgawhary signals that the DOJ is not only pursuing improper...more

Gentleman’s Club Owner Hit With Fraud Penalty

A new Tax Court decision just came out – Potter v. Commissioner, TC Memo 2014-18. The case involved a “gentleman’s club” owner in Michigan. In December 2006 IRS special agents engaged in an undercover investigation of...more

Where Do You Hide $1 Trillion?

According to a recent report by Global Financial Integrity (GFI), a Washington-based group committed to exposing financial corruption, developing countries lost almost $1 trillion to crime, corruption and tax evasion in 2011....more

At Risk Cash Transaction For Business Clients—The Computers Are Watching

It is Monday morning at your law office, and you get a telephone call from one of your smaller business clients. He is frantic to say the least. Over the weekend, his employee payroll checks bounced at the bank as well as...more

White Collar Watch - November 2013

In This Issue: - The true cost of fines: Bills would address tax break for corporate fines - Senate approves new protection for criminal antitrust whistleblowers - Justice Department sinks ex-Navy...more

Top 3 Tax Mistakes

There are a lot of ways to get into hot water with state and federal revenue regulators. But, in my experience, three mistakes are most common. ...more

Small businesses beware: IRS deploys "big data" to scrutinize cash transactions

In Brief - The IRS has signaled its intent to prosecute more small businesses for relatively low-value tax violations. - In doing so, the IRS has increased its reliance on data-driven analyses of the...more

White Collar Watch - October 2013

In This Issue: - Small businesses beware: IRS deploys “big data” to scrutinize cash transactions - Google’s scanning of emails may constitute wiretapping: Federal District Court denies Google’s motion to dismiss...more

Nevada Businessman Sentenced to Nine Years in Prison

Multiple outlets are reporting that on October 15, 2013, William Reed, a Nevada businessman, was sentenced to nine years in federal prison after pleading guilty to conspiracy to defraud the United States, tax evasion, and...more

Religious Institutions Update: May 2013

Intellectual property is a legal construct referring to creations of the mind for which exclusive rights are recognized. Common types include copyrights, trademarks, patents, industrial design rights, trade dress and,...more

Third Circuit Court of Appeals Affirms Tax Court Decision on CARDS Tax Shelter

On February 25, 2013, the United States Court of Appeals for the Third Circuit in the case of Crispin v. Commissioner, ___ F.3d ___, 2013 U.S. App. LEXIS 3852 (3d Cir. 2013), available here, affirmed the decision of the Tax...more

Gaming Legal News - January 17, 2013 • Volume 6, Number 2

In This Issue: - I-GAMING IN THE UNITED STATES VERSION 2013: BACK TO THE STATES? Optimism had inched higher that the United States would shift its i-gaming policy from a prohibitory approach to allowing some form of...more

Avoiding “Responsible Person” Liability For Payroll and Sales Taxes

One benefit of conducting business through a corporation, limited liability company or other limited liability entity is the “shield” from personal liability that these entities generally afford stockholders, directors and...more

White Collar Watch - October 2012

In This Issue: - SEC Issues Cease and Desist Order Against Goldman Sachs for Pay-to-Play Violations page 1 - 3 - A Change in Tack: The Government Turns its Attention Away from Pharmaceutical Companies and Toward...more

Tax Evasion Case of 5 Restaurant Owners

The 5 owners of the Nifty Fifty’s chain of restaurants were charged by the IRS for tax evasion, according to US Attorney Zane Memeger. The case was announced by Memeger, IRS Acting Special Agent in Charge Akeia Connor with...more

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