News & Analysis as of

Income Taxes Criminal Investigations

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Foodman CPAs & Advisors

IRS Voluntary Disclosure Practice

Taxpayers that have willfully failed to comply with tax or tax-related obligations may be able to resolve their non-compliance and limit their exposure to criminal prosecution by filing an application to the IRS Voluntary...more

Ballard Spahr LLP

Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent...

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In this episode, we are joined by Special Agent Jonathan Schnatz, Senior Analyst with IRS Criminal Investigation. Special Agent Schnatz will discuss his work with an international law enforcement and tax compliance group, and...more

Gray Reed

The IRS is Attacking Abusive Trust Arrangements

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Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more

McDermott Will & Emery

IRS Criminal Investigation Division Is on the Hunt for Malta Pension Plan Participants and Promoters

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There has been a growing trend of US taxpayers contributing non-cash assets, such as appreciated property, securities and cryptocurrency, into Maltese pension plans since the US-Malta Tax Treaty went into effect in 2011....more

Freeman Law

Can You Go to Jail for Not Paying Your IRS Taxes?

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Taxpayers routinely ask me if they can go to jail for not paying their federal income taxes. Admittedly, the bar is not that high for felony tax evasion—the government must only prove three elements: (i) willfulness; (ii)...more

Freeman Law

Tax Court in Brief | Pocock v. Commissioner | Equitable Innocent Spouse Relief Under 6015(f)

Freeman Law on

Tax Litigation: The Week of June 6th, 2022, through June 10th, 2022 Musselwhite v. Commissioner, T.C. Memo. 2022-57 | June 8, 2022 | Ashford, J.| Dkt. No. 14380-16 Spencer v Commissioner, T.C. Memo. 2022-8 | June 7, 2022 |...more

Oberheiden P.C.

What Tax Preparers Need to Know Before Sitting for an IRS CI Interview

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The Internal Revenue Service’s Criminal Investigation Division (IRS CI) is targeting tax preparers or the ones who prepare tax returns in 2022. IRS CI is focusing its efforts on tax preparers who underreport their clients’...more

Freeman Law

IRS Criminal Investigation’s Top Ten Cases of 2021

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Many (if not most) people and organizations approach a new year by setting new goals or implementing changes. This exercise, however, requires a reflection on the previous year’s events, successes, and failures. And...more

Gray Reed

IRS-Criminal Investigations Counts Down the Top 10 Cases of 2021

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“The investigative work of 2021 has all the makings of a made for TV movie – embezzlement of funds from a nonprofit, a family fraud ring that stole millions in COVID-relief funds and a $1 billion Ponzi scheme used to buy...more

Freeman Law

Yet Another Streamlined Filing Turns into a Criminal Indictment, Implicating Former CPA and Businessman

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A recent IRS Criminal Investigation press release announced an indictment against a businessman charged with defrauding the United States by not disclosing offshore assets, failing to report income to the IRS, and submitting...more

Freeman Law

The Tax Court in Brief - September 2021 #3

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Tax Court Litigation: The Week of September 13 – September 17, 2021 - Donna M. Sutherland v. Comm’r, No. 3634-18, T.C. Memo 2021-110 | September 16, 2021 | Lauber | Dkt. No. 3634-18 - Short Summary: This is an...more

Freeman Law

[Webinar] Freeman Law International Tax Symposium – General Attendee - November 18th - 19th, 8:00 am - 5:00 pm CST

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Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more

McDermott Will & Emery

Key Takeaways | Cryptocurrency Global Tax Enforcement: What Investors and Companies in the Industry Need to Know NOW

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During a recent program discussing the latest government enforcement efforts related to cryptocurrency, we spoke with Gary Alford, one of the leading Internal Revenue Service (IRS) agents in their crypto enforcement efforts,...more

McDermott Will & Emery

[Webinar] Cryptocurrency Global Tax Enforcement: What Investors and Companies in the Industry Need to Know NOW - June 28th, 12:00...

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Following the US Internal Revenue Service’s (IRS) announcement of “Operation Hidden Treasure,” companies and individuals should prepare for increased scrutiny of virtual currency transactions. Unveiled in March, the operation...more

Oberheiden P.C.

Eleven of the IRS's Enforcement Priorities During the 2021 Tax Season

Oberheiden P.C. on

It is tax season once again. While the Internal Revenue Service (IRS) has extended this year’s filing deadline to May 17, 2021 for individuals, businesses must still file by April 15, and all U.S. taxpayers must ensure that...more

Freeman Law

IRS Publishes Proposed BBA Regulations on Special Enforcement Matters

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Over 5 years ago, then President Obama ushered in sweeping changes to the method and manner in which partnerships are audited and partnership tax is assessed and collected through his signing of H.R. 1314, the Bipartisan...more

Saul Ewing LLP

Supreme Court Holds President Is Not Categorically Immune to State Court Subpoena

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In last week’s decision in Trump v. Vance, the Supreme Court addressed for the first time whether a state District Attorney’s Office can issue a state criminal subpoena to a President. Relying on historical examples dating as...more

Faegre Drinker Biddle & Reath LLP

Supreme Court Decides Trump v. Vance

On July 9, 2020, the U.S. Supreme Court decided Trump v. Vance, No. 19-635, holding that President Donald Trump was required to respond to a state subpoena of his tax returns and other financial information because “Article...more

Ballard Spahr LLP

IRS CI Highlights International Efforts to Tackle Cryptocurrency Abuse, Money Laundering and Tax Evasion

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ABA Tax Fraud Panel to Discuss IRS CI and Crypto Criminals - The Internal Revenue Service – Criminal Investigation (IRS CI) has made it clear that it is focusing on the abuse of digital currencies to further tax evasion,...more

A&O Shearman

IRS Issues Virtual Currency Tax Guidance on Forks and Airdrops

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On October 9, 2019, the Internal Revenue Service (the “IRS”) issued Revenue Ruling 2019-24 (the “Revenue Ruling”) and questions and answers (the “Q&A” and, together with the Revenue Ruling, the “Guidance”) addressing certain...more

Rosenberg Martin Greenberg LLP

The Crackdown on Cryptocurrency

We all read the headlines. Virtual currencies are a hot button topic. Even Facebook is developing their own virtual currency. It is easy to understand the attraction. The use of a virtual currency is anonymous. Account...more

McDermott Will & Emery

Watch Your Mailbox: IRS Letters Warning of Cryptocurrency Non-Compliance on Their Way

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On July 26, 2019, the Internal Revenue Service (IRS) issued a press release informing the public that it is sending more than 10,000 letters to taxpayers with potentially unreported (or misreported) virtual currency...more

Foodman CPAs & Advisors

IRS gives Internal Revenue Manual Voluntary Disclosure Consideration if…….

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When IRS reviews a criminal tax case, consideration is given to various factors such as whether a voluntary disclosure was made, whether prosecution exists, the health, age and mental condition of the Taxpayer and whether a...more

Foodman CPAs & Advisors

Do You Know What an IRS Criminal Investigation is?

The US taxes its citizens and permanent residents on their worldwide income regardless of where they live or how long they’ve lived outside of the US. There is only one other country in the world that operates like the US –...more

Robinson+Cole Data Privacy + Security Insider

Former IRS Employee Reports to Prison for Identity Theft and Fraud

Nakeisha Hall was sentenced in federal district court in August to serve nine years and two months in prison after she plead guilty for crimes she committed while working for the IRS Taxpayer Advocate Service. Instead of...more

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