News & Analysis as of

Internal Revenue Service Enforcement Actions

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Buckingham, Doolittle & Burroughs, LLC

What to Do If Your Business Receives a Tax Audit

When your business receives an audit engagement letter, don’t panic. While an audit may be time-consuming, costly, and invasive, having an experienced advocate on your side to navigate you through the process and represent...more

Cadwalader, Wickersham & Taft LLP

Crypto: Give Unto Caesar What Is Caesar’s

Earlier this year the U.S. Department of Justice (“DOJ”) brought USA v. Ahlgren, its first crypto case with tax evasion allegations unrelated to another crime, demonstrating the DOJ’s willingness to pursue stand-alone crypto...more

Polsinelli

Blockchain+ Bi-Weekly - April 2024 #2

Polsinelli on

The focus in Web3 law the past few weeks has been on jurisdictional issues when litigating matters involving borderless digital asset transactions. This is expected to be an ongoing issue, as courts work through these...more

Kohrman Jackson & Krantz LLP

IRS Cracks Down on High-Income Earners

Since the Internal Revenue Service (IRS) has received its supplemental funding under the Inflation Reduction Act, the IRS has continuously focused on high-income earners, partnerships, and large corporations. Under its most...more

ArentFox Schiff

Investigations Newsletter: Deputy Attorney General Monaco Warns Industries: “Fraud Using AI is Still Fraud”

ArentFox Schiff on

On March 7, Deputy Attorney General Lisa Monaco delivered the keynote remarks at the American Bar Association’s (ABA) 39th National Institute on White Collar Crime. She noted that artificial intelligence (AI) “holds great...more

Seward & Kissel LLP

DOJ Announces Launch of New “Gap-Filling” Whistleblower Program

Seward & Kissel LLP on

On March 7, 2024, Deputy Attorney General Lisa Monaco delivered the keynote remarks at the American Bar Association’s 39th National Institute on White Collar Crime. In her address, she announced a new, nationwide...more

A&O Shearman

Announcement of new DOJ Whistleblower Policy

A&O Shearman on

On March 7, 2024, Deputy Attorney General Lisa Monaco announced a new 90-day pilot program at the Department of Justice (DOJ) to incentivize whistleblowers. The program is inspired by and generally follows similar programs...more

Mayer Brown

US Department of Justice Announces Sprint Towards New Whistleblower Reward Program

Mayer Brown on

On March 7, 2024, the Deputy Attorney General of the US Department of Justice (“DOJ” or “Department”) announced a pilot program to encourage whistleblowers to report evidence of high-priority white collar crimes with the...more

Gray Reed

Travel Alert: How IRS Debt Can Affect Your Passport

Gray Reed on

By law, the IRS certifies taxpayers with “seriously delinquent” tax debts to the Department of State affecting passport status and renewal when certain conditions or thresholds are met. The IRS will send a Notice called a...more

BakerHostetler

No Further Warnings - Prosecutors Bring First Pure Legal Digital Asset Tax Indictment; More Criminal Cases to Come

BakerHostetler on

After years of explicitly warning taxpayers that failing to report or underreporting income from transactions involving digital assets would lead to criminal charges, federal prosecutors are now beginning to follow through on...more

Foley Hoag LLP - White Collar Law &...

Criminal Tax Enforcement – What to Look For in 2024

IRS enforcement activity remained strong in 2023, with the volume of investigations and prosecutions initiated holding steady from 2022. Despite the substantial funding boost provided by the Inflation Reduction Act, with some...more

ArentFox Schiff

Five, Six, Seven, Eight, Nine, Ten . . . Will We Love 2024? Top 10 Tax Issues for the Year

ArentFox Schiff on

The 2024 election year promises to make taxes front-of-mind for many business and individual taxpayers. Beyond the election, there are other note-worthy developments, along with several highly anticipated tax law cases that...more

Gray Reed

IRS Seeks to Enforce Summons Related to Deferred Sales Trust

Gray Reed on

We have previously spoken about monetized installment sales (“MISTs”) on Dollars & Sense.  According to the IRS, these structures typically seek to defer gains associated with the sale of an appreciated asset through the use...more

BakerHostetler

Employers Beware: Broad Confidentiality and Severance Clauses May Violate Whistleblower Protection Laws

BakerHostetler on

Employers should check their confidentiality and severance agreements for a common oversight that, for some, is becoming a costly error. Recent enforcement activity by the Securities and Exchange Commission (SEC) of Rule...more

Polsinelli

CPA gets 25 years for Promoting Conservation Easement Deductions

Polsinelli on

Judge Batten, Chief United States District Judge for the Northern District of Georgia, handed down lengthy sentences in the first-of-its-kind criminal trial related to syndicated conservation easements (“SCEs”). On January...more

BakerHostetler

USDC Integrations Announced; Crypto Guidance Published by IRS, EU Banking Authority; Crypto Firm Consents to $8M Penalty; Illicit...

BakerHostetler on

USDC Report Published, Crypto Firms Announce USDC Integrations - Circle, the U.S. fintech company that manages the stablecoin USDC, recently released the “State of the USDC Economy” report, highlighting the “efforts to...more

Skadden, Arps, Slate, Meagher & Flom LLP

With New Technology and New Hires, the IRS Aims To Audit More Effectively While Improving Taxpayer Services

New Funding, New Focus - With some $80 billion in initial funding from the Inflation Reduction Act (IRA), the Internal Revenue Service (IRS) began ramping up taxpayer services, issue resolution planning, compliance and...more

Rumberger | Kirk

Protecting Your Business From Widespread ERC Scams

Rumberger | Kirk on

Misinformation and widespread scams have created pitfalls for businesses regarding the employee retention credit - The Employee Retention Credit (ERC) has been one of the most discussed tax topics of 2023. Although...more

Allen Barron, Inc.

How Does the IRS Use AI to Identify Tax Cheats?

Allen Barron, Inc. on

Could Artificial Intelligence (AI) increase the likelihood of an IRS audit in your future? How does the IRS use AI to identify US taxpayers who attempt to hide assets, under-report income or otherwise cheat the IRS? In...more

Gray Reed

Release the Kraken Tax Transaction Information

Gray Reed on

On June 30, 2023 the District Court in the Northern District of California granted a petition to enforce the cryptocurrency exchange Kraken to release customer information.  Specifically, Kraken was ordered to produce the...more

Allen Barron, Inc.

IRS Focuses Scrutiny on High-Income Taxpayers, Partnerships and Corporations

Allen Barron, Inc. on

New issues come into focus as the IRS focuses scrutiny on high-income taxpayers, partnerships and corporations, as well as those who promote the abuse of tax rules.  The IRS has formally given notice that it intends to...more

Gray Reed

The IRS is Hiring an Army to Audit Corporations, Partnerships, and High-Income Individuals

Gray Reed on

The IRS has been understaffed for many years, and this has led to a decline in the number of audits conducted.  The personnel shortage has also made it difficult to keep up with the growing complexity of the tax code and to...more

Gray Reed

The IRS is Attacking Abusive Trust Arrangements

Gray Reed on

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

Polsinelli

Conservation Easements: Palpable Fraud or Honest Mistakes? A Federal Jury Returns a Split Verdict

Polsinelli on

On September 22, 2023 a federal jury convicted two promoters, CPA Jack Fisher and attorney James Sinnott, in the Department of Justice’s (“DOJ”) first criminal trial over allegedly abusive syndicated conservation easements...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Rolls Out Long-Planned Strategy Targeting Large Partnerships and High-Wealth Individual Taxpayers

On September 8, 2023, Internal Revenue Service (IRS) Commissioner Danny Werfel announced the rollout of a coordinated enforcement strategy that will involve audits of returns filed by 75 of the largest partnerships operating...more

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