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Follow the money - the Criminal Finances Bill

The Criminal Finances Bill sets out measures to combat money laundering and tax evasion that will also affect corporate compliance requirements, particularly in the finance and professional services sectors....more

Sonhos Interrompidos - Como uma não conformidade tributária pode destruir o Sonho Americano de imigrantes não registrados - Parte...

Panorama - A Parte I desta série teve enfoque no pesadelo e problema imprevisto de declarações de impostos não apresentadas para imigrantes não registrados. As consequências de "empurrar o problema com a barriga"...more

Broken Dreams - How Tax Non-Compliance Can Destroy the American Dream of Undocumented Immigrants - Part 2

Part I of this series focused on the unforeseen nightmare and problem of unfiled tax returns for undocumented immigrants. The consequences of “kicking the can down the road”, will have significant legal and financial...more

Case Note: Crime Doesn’t Pay and Taxes are Still Due

In a case involving criminal forfeiture of stock option profits, the Court of Appeals for the Federal Circuit has held that no deduction is allowed for $44 million in forfeited stock option gains on which tax was previously...more

¡Primera Convicción de FATCA!

El 9 de Mayo del 2016, el Departamento de Justicia (DOJ) anunció su primera convicción usando FATCA. Parece ser el principio de procesos penales por el DOJ contra violaciones aparentes o presuntas de los requisitos de...more

Asset Forfeiture Reform Bill Moving Through Congress

The “Restraining Excessive Seizure of Property through the Exploitation of Civil Asset Forfeiture Tools Act” (tortuously abbreviated as the RESPECT Act) (H.R. 5523) continues to make its way through Congress, with a markup ...more

IRS and DOJ are Reviewing and Scrubbing Offshore Accounts Data to Build Civil and Criminal Cases

During the June 24, 2016 Tax Controversy Conference held at New York University, officials from both the Department of Justice (DOJ) and the Internal Revenue Service (IRS) emphasized their focus on analyzing the avalanche of...more

Legislative Update

With negotiations on the budget bill (HB 1030) still continuing outside the public view, this week the General Assembly focused on other issues. Tax Proposals; Services Tax Clarifications and New Market Jobs Act - ...more

Recreational Cannabis — Section 280E and Tax Efficient Structuring

Recreational cannabis businesses operate in a world of conflicting state and federal laws. Several states have legalized recreational cannabis, yet, under federal law, cannabis remains an illegal Schedule I drug under the...more

“Spider Webs”, “Panama Papers” and IRS

IRS has asked involved U.S. taxpayers to come forward before IRS reads and dissects the “Panama Papers”. IRS will “plan how to use the huge trove of leaked documents to catch criminals — and urged Americans to come clean now...more

Justice Department’s First FATCA Prosecution Yields Guilty Plea

On May 9, 2016, the Justice Department announced that Gregg R. Mulholland, a dual U.S. and Canadian citizen and owner of an offshore broker-dealer and investment management company based in Panama and Belize, pleaded guilty...more

First FATCA Conviction!

On May 9, 2016, the Department of Justice (DOJ) announced its first FATCA conviction. It appears to be the beginning of criminal prosecutions by the DOJ against apparent or alleged violations of FATCA reporting requirements....more

The Panama Papers: Are You at Risk?

The recent document breach of unprecedented size (2.6 terabytes) from the Panamanian law firm Mossack Fonseca—known as “The Panama Papers”—poses various significant risks to corporations, private organizations, individual...more

Panama Papers: Prosecutors Launch Investigations

When a scandal hits the media like the Panama Papers leak of 11.5 million confidential legal records, we all know what to expect. Criminal investigations, regulatory responses, and of course, congressional hearings of some...more

Georgia couple prosecuted for filing fraudulent tax records

The filing of fraudulent tax returns continues to be a serious problem in this country. Last year alone, the IRS has admitted that up to 720,000 taxpayers were victims. Last week, a Georgia couple pled guilty to filing...more

The Panama Effect: UK Government accelerates proposals to criminalise failure to prevent tax evasion

10 considerations for professionals and corporates worldwide in advance of the new law. Overview - In a move widely seen as a response to the so-called “Panama Papers” revelations, the UK Government has enhanced...more

As Panama Papers Illustrates, IRS Discovery of Undisclosed Assets Just a Matter of Time

As the recent leak of the "Panama Papers" reminded the world, some secrets don't keep well, particularly those related to undisclosed foreign assets. And once a person's identity is disclosed as a holder of undisclosed...more

The “Panama Papers” and the Secret World of Shell Corporations - Reducing Liability Exposure and Seeking Insurance Coverage

A leak of 11.5 million documents from a law firm in Panama may implicate politicians, criminals, and celebrities in sheltering of fortunes in offshore tax havens through the use of shell companies. Called the “Panama Papers,”...more

Confirming That No Country Is “Off Limits,” DOJ Secures Guilty Pleas From 2 Cayman Islands Financial Institutions for Tax Evasion

In its first-ever conviction of a non-Swiss financial institution for tax evasion conspiracy, the Justice Department announced today that two Cayman Islands firms pleaded guilty in a U.S. court to conspiring to hide more than...more

Retroactive Tax Law Provides Tax Benefits for Victims of Wrongful Incarceration

At the end of 2015, Congress eliminated some of the uncertainty regarding the tax treatment of damages for wrongful imprisonment. Newly enacted Internal Revenue Code section 139F provides that gross income does not include...more

Offshore Tax Enforcement Update: DOJ Announces Criminal Charges Against Bank Julius Baer

The U.S. government has filed criminal charges against another Swiss Bank — Bank Julius Baer — and simultaneously secured guilty pleas from two Julius Baer bankers who had been fugitives for the past five years. Pursuant to...more

DOJ’s Latest Offshore Tax Case Shows Expatriates Who Renounce U.S. Citizenship Not Immune From Prosecution

An individual residing in Switzerland since 2007, who apparently renounced his U.S. citizenship four years ago, was convicted today in federal court of one count of filing a false U.S. income tax return. According to a...more

DOJ Tax Division Chief Outlines Enforcement Priorities for 2016

In speech delivered on January 29, 2016, at the American Bar Association’s Tax Section Midyear Meeting, Acting Assistant Attorney General Caroline D. Ciraolo of the Justice Department’s Tax Division recapped her agency’s...more

IRS 80- Swiss Banks 0

The formal IRS/Department of Justice (DOJ) Swiss Bank Program has concluded with 80 Swiss banks coming forward. The banks agreed to provide information about personnel, depositors and advisors who were participated in or...more

Cash for Scalps: Governor Cuomo Announces New Round of Grants for Tax Prosecutions

Last week, Governor Cuomo announced the latest round of grants to district attorneys’ offices in 29 New York State counties under the Crimes Against Revenue Program (also known as “CARP”). The program provides substantial...more

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