Tax Criminal Law

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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

Tax Day Brings Barrage of Criminal Tax Charges and Warnings

With “Tax Day” upon us, the Justice Department’s Tax Division and U.S. Attorney’s Offices around the country have unleashed an avalanche of press releases warning would-be tax cheats of the severe criminal and civil...more

With April 18 Just Days Away, DOJ’s Tax Division Warns Would-Be Tax Cheats

With “Tax Day” fast approaching, the Justice Department’s Tax Division has issued a stern warning of its own to taxpayers thinking of cheating on their taxes. In a press release entitled “Justice Department Reminds Taxpayers...more

As Tax Day Approaches, Justice Department and IRS Increase Intensity of Public Warnings

It is well-known that the Justice Department and Internal Revenue Service increase the frequency and intensity of their press releases announcing tax charges as “Tax Day” approaches (which is April 18 this year), so as to...more

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

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

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

Like Santa Claus, the IRS Keeps a List of Who Has Been Naughty or Nice: It Is the Time of Year When the IRS’s Naughty List Gets...

Every year, around the April 15 individual tax return filing deadline, a story appears in the press highlighting the tax woes of famous people. The Government undoubtedly issues these press releases to encourage taxpayers to...more

Practical Tips to Avoid Being Caught in an IRS Phishing Trap

As a follow-up to our recent discussion of IRS-related phishing attempts, here are a few quick tips to stay out of the phishing traps: ..In general, the IRS does not communicate with taxpayers via e-mail, so any time...more

Spear Phishing E-mail Scheme Surges For W-2 Forms

In the midst of this tax season, a number of companies have fallen victim to the latest spear phishing e-mail scheme, resulting in the unauthorized disclosure of their employees’ W-2 information and learning the hard lesson...more

"IRS Issues Alert on Phishing Scheme to Obtain Payroll Data"

The Internal Revenue Service (IRS) recently issued an alert regarding a phishing email scheme in which cybercriminals pose as governmental officials or company executives and request employee payroll and tax data, including...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

Payroll and HR Professionals Beware: Phishing Schemes Are Now Trying to Lure You

ALERT, ALERT!!!! The IRS has renewed a consumer alert for e-mail schemes regarding phishing and malware incidents targeted at individuals. That renewal came after an approximate 400 percent surge in such incidents so far this...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

CPA-Client Privilege Doesn't Extend to Criminal Proceedings

It's Monday morning and your client, who recently retained you for estate tax planning advice, informs you that the IRS is auditing her income tax returns from the past three years. In reviewing her tax returns and financial...more

South Carolina Legislative Update

The South Carolina General Assembly is preparing for their second regular session and will officially convene on January 12, 2016. The House and Senate’s various committees have diligently debated the following during the...more

Three More Non-Prosecution Agreements with Swiss Banks for a Total Penalty of $20 Million

Three more Swiss banks have reached resolutions with the Justice Department under its Swiss Bank Program – Bank La Roche, St. Galler Kantonalbank AG (SGKB), and E. Gutzwiller & Cie, Banquiers. To resolve their respective...more

IRS Seeks Identities of Americans with Undisclosed Belize Bank Accounts

Americans with secret accounts in Belize should take notice: the government is looking for you. The U.S. Department of Justice on September 15 filed a petition in federal court in Miami seeking permission to issue summonses...more

Check Cashing, Tax Evasion, Structuring and Asset Forfeiture; The Making of a Bad Day

The following fact pattern should is representative of a tax evasion and structuring case. A taxpayer receives checks in the ordinary course of business from customers. Some of those checks are deposited into the business...more

Swiss Banks Bank Zweiplus and Banca Stato Have Entered into Non-Prosecution Agreements under the DOJ’s Swiss Bank Program

Two more Swiss banks have reached resolutions with the Justice Department under its Swiss Bank Program. Yesterday, DOJ announced that bank zweiplus ag (Bank Zweiplus) and Banca dello Stato del Cantone Ticino (Banca Stato)...more

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