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UK Criminal Finances Act 2017: A Dechert "Dirty Money" Trilogy

by Dechert LLP on

Part One: "A Fistful of Tax Dollars" - A New Corporate Offence of Failure to Prevent the Facilitation of Tax Evasion.. The Criminal Finances Act 2017 represents a further significant development in the approach to the...more

Tax Round Up - May 2017

by Proskauer Rose LLP on

Budget and Finance Bill - General Election – Finance Bill (No.2) 2017 Curtailed - The Finance (No.2) Bill received Royal Assent on 27 April 2017, becoming the Finance Act 2017. However, as a result of Theresa May...more

MoFo New York Tax Insights - Volume 8, Issue 5

by Morrison & Foerster LLP on

Final 2017-18 New York State Budget Bill Enacted - The New York State Budget Bill was enacted by the New York State Legislature and signed into law by Governor Andrew M. Cuomo. S. 2009-C, A. 3009-C. Among the Governor’s...more

Corporate criminal liability risk increases for financial services

by Allen & Overy LLP on

The Criminal Finances Act 2017, which received Royal Assent last week, contains the largest expansion of UK corporate criminal liability since the Bribery Act 2010 and one of the most significant overhauls of money laundering...more

2016 – A Bad Year For Bad Guys in Energy

by Gray Reed & McGraw on

Let’s look back at a cavalcade of crooks, criminals and miscreants who met up with justice in 2016. We do it to be reminded of the others who will be lurking in the 2017 shadows....more

California Ballot 2016: Pros and Cons of Props 62-67

by Lewitt Hackman on

This is part three of our ongoing series, California Ballot 2016, summarizing each of the 17 state-wide measures voters will encounter on the November ballot. Click these links: Props 51-56, or Props 57-61 to catch up on the...more

¡Primera Convicción de FATCA!

by Foodman CPAs & Advisors on

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

Recreational Cannabis — Section 280E and Tax Efficient Structuring

by Lane Powell PC on

I. The Conflict: The long arm of federal law Recreational cannabis businesses operate in a world of conflicting state and federal laws. Several states have legalized recreational cannabis, yet, under federal law, cannabis...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

Panama Papers: Prosecutors Launch Investigations

by Michael Volkov on

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

Phishing Season Opens for 2016 Tax Filings – Beware of “W-2 Phishing Scams”

by K&L Gates LLP on

Tax season brings many headaches, but none as miserable as sophisticated scammer efforts to steal employee W-2 information. Using social engineering and modest technological tools, a “spear phishing” attack seeks to trick...more

$10,000 in Cash Receipts? Heightened Penalties for Failure to File Form 8300 Within 15 Days

Any person who, in its trade or business, receives cash in the amount of more than $10,000 in a single transaction or a series of related transactions must file Form 8300, Report of Cash Payments Over $10,000, Received in a...more

European Competition Law Newsletter – July 2015

by McGuireWoods LLP on

On 24 June 2015, the UK Competition and Markets Authority (CMA) was defeated in its first attempt at convincing a jury to convict individuals for the UK criminal “cartel offence”. The jury was not persuaded that the two...more

IRS Focus: Offshore Tax Evasion Tops Dirty Dozen List

by Sanford Millar on

The IRS issued two New Releases this week that restate its focus on offshore tax evasion. The first was January 29, 2015 which followed the First International Criminal Tax Symposium....more

Guindon: SCC Hears Arguments in Penalty Case

by Dentons on

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

by Blank Rome LLP on

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

by DLA Piper on

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

by Shearman & Sterling LLP on

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?

by Moskowitz LLP on

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

by Michael Volkov on

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...

by Blank Rome LLP on

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

by Stinson Leonard Street on

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

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

by White & Case LLP on

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

by Gray Reed & McGraw on

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

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