News & Analysis as of

Internal Revenue Service John Doe Investigation

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.  
Fox Rothschild LLP

IRS Going All in on Use of ArtificiaI Intelligence

Fox Rothschild LLP on

The IRS issued a news release today announcing a continued and more focused use of Artificial Intelligence (AI) to audit partnerships, large corporations and alleged tax shelter promoters. The news release follows...more

BakerHostetler

Kraken Loses Bid To Avoid Turning Over Customer Information to IRS

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In a recent ruling, a California federal judge held that Kraken, an online cryptocurrency exchange program, has to turn over user information to the IRS as a result of a John Doe summons originally served on Kraken in 2021....more

Cadwalader, Wickersham & Taft LLP

IRS’s Crypto John Doe Summons Expanded While Harper Fights Back

Since at least 2016 the IRS has been ferreting out taxpayers who failed to report their taxable gains from cryptocurrency transactions by issuing John Doe summonses to crypto exchanges and dealers. A John Doe summons enables...more

Freeman Law

IRS Wins Ex-Parte Petition for Another Crypto John Doe Summons

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On September 21, 2022, the U.S. District Court for the Southern District of New York granted the IRS’s ex-parte motion for leave to serve a John Doe summons to M.Y. Safra Bank after the IRS’s investigation into digital asset...more

BakerHostetler

Crypto and NFT Firms Make Announcements; Treasury Interprets Crypto Reports; Crypto Enforcement Actions by CFTC, SEC, IRS, DOJ and...

BakerHostetler on

Exchange Reaches Agreement to Sell Assets; New Crypto Products Launch - In a press release this week, Voyager Digital, a cryptocurrency exchange that recently filed for Chapter 11 bankruptcy, announced that it selected the...more

BakerHostetler

The Tax Man Isn't Leaving: The IRS Continues to Issue John Doe Summonses Relating to Virtual Currency Transactions

BakerHostetler on

Key Takeaways - ..A court approved the issuance of a John Doe summons by the IRS to a bank aimed at identifying individuals who are potentially avoiding their income tax obligations relating to cryptocurrency...more

Freeman Law

Tax Court in Brief | Lamprecht v. Comm’r | Qualified Amended Return and Foreign Banking Reporting

Freeman Law on

Tax Litigation:  The Week of August 29th, 2022, through September 2nd, 2022 Sparta Pink Property, LLC v. Comm’r, T.C. Memo. 2022-88 | August 29, 2022 | Lauber, J. | Dkt. No. 12114-20 Pressman v. Comm’r, T.C. Summ. Op....more

Goodwin

Central District of California Authorizes Service of John Doe Summons on Cryptocurrency Dealer - Update

Goodwin on

​​​​​​​On August 15, 2022, the United States District Court for the Central District of California authorized the IRS to serve a “John Doe” summons on Ox Labs Inc., a cryptocurrency prime dealer doing business as SFOX....more

Goodwin

Central District of California Authorizes Service of John Doe Summons on Cryptocurrency Dealer

Goodwin on

​​​​​​​On August 15, 2022, the United States District Court for the Central District of California authorized the IRS to serve a “John Doe” summons on Ox Labs Inc., a cryptocurrency prime dealer doing business as SFOX. ...more

BakerHostetler

Top 5 Digital Asset Litigation and Investigation Trends of 2022

BakerHostetler on

Cryptocurrency and digital assets have kept the courts and regulators busy as digital assets continue to pose new questions and challenges for anyone involved in their sale, trade or development. The following trends have...more

BakerHostetler

The Tax Man Is Back: IRS Issues First John Doe Summons in 2022 to Major Crypto Platform, Seeking Treasure Trove of Information on...

BakerHostetler on

Key Takeaways: ..The IRS issued its fourth John Doe summons against digital asset platform sFOX, seeking information regarding user identity and transaction activity over $20,000. ..The use of John Doe summonses...more

Gray Reed

IRS Continues to Hunt for Cryptocurrency Investors with John Doe Summonses

Gray Reed on

The IRS knows it has a problem, in that it knows there are far more cryptocurrency transactions than are being reported on tax returns. The IRS may also get an $80 billion increase in funding for enforcement that will help...more

Whitcomb Selinsky, PC

John Doe Summons Doesn't Violate Attorney Client Privilege

Whitcomb Selinsky, PC on

On April 24, 2020, the U.S. Court of Appeals for the Fifth Circuit published its opinion in Taylor Lohmeyer Law Firm P.L.L.C. v. United States. The Fifth Circuit court held that the Taylor Lohmeyer Law Firm (the law firm OR...more

Foodman CPAs & Advisors

The IRS Is Cracking Down On Cryptocurrency Tax Reporting

If you’ve engaged in cryptocurrency or other virtual currency transactions worth $20,000 in any one year between 2016 and 2020, the IRS wants to hear from you. The IRS believes thousands of taxpayers are not telling the...more

Gray Reed

Guidelines for Protecting Privilege in Tax Cases

Gray Reed on

Lawyers, tax or otherwise, understand that privileged information must be protected to encourage a full and frank dialogue that might not occur without confidentiality.1 Tax information, in particular, contains some of the...more

Roetzel & Andress

IRS Asks Major Crypto Exchange For Users’ Identities And Data

Roetzel & Andress on

Earlier this month, the United States District Court, Northern District of California approved the Internal Revenue Service’s (IRS) request to execute a “John Doe” summons on the parent company of popular cryptocurrency...more

McDermott Will & Emery

Finding John Doe, Part II: IRS Secures Another Victory to “Root Out” Virtual Currency Tax Noncompliance

The Internal Revenue Service (IRS) has scored another significant victory in its rapidly increasing virtual currency tax enforcement efforts. On May 5, 2021, the US District Court for the Northern District of California...more

Gray Reed

The IRS is Hunting for Cryptocurrency Investors with John Doe Summonses

Gray Reed on

The IRS has several tools in its arsenal to encourage compliance and audit and enforce those it believes are failing to comply.  One of the most powerful tools is the John Doe summons. A regular IRS summons seeks information...more

McDermott Will & Emery

DOJ and IRS’ Analysis of Crypto Records and Work with Private Experts and International Partners Leads to Arrest

McDermott Will & Emery on

US law enforcement continues to make no secret of their efforts to work closely with experts and overseas partners to prosecute those involved in virtual currency transactions who attempt to rely on its purported anonymity to...more

McDermott Will & Emery

Finding John Doe: IRS Steps up Enforcement Efforts to Take the Anonymity Out of Virtual Currency

McDermott Will & Emery on

The Internal Revenue Service (IRS) is stepping up its virtual currency enforcement, and taxpayers who have engaged in a cryptocurrency transaction should immediately assess any potential tax implications as the IRS has...more

Foodman CPAs & Advisors

An IRS “John Doe” Summons is a Powerful Weapon that can Puncture Attorney-Client Privilege

An individual that provides information to an attorney may normally assume that the information provided to the attorney will be kept confidential under the attorney-client privilege.  That said, according to the Internal...more

Foodman CPAs & Advisors

IRS using Data Analytics to Uncover Criminal Arrangements

IRS-Criminal Investigation (IRS-CI) is a federal agency department specifically authorized to investigate and prosecute federal income tax crimes.  IRS-CI uses data analytics such as models, algorithms, and the millions of...more

Mitchell, Williams, Selig, Gates & Woodyard,...

The Taxpayer First Act Changes IRS Powers in Ways Important to Your Civil and Criminal Tax Clients

On July 1, 2019, President Trump signed the Taxpayer First Act (“Act”), which includes a host of important expanded taxpayer protections ranging from adjustments to criminal tax seizures, to John Doe summonses, to the...more

Jones Day

IRS Summons for Law Firm Client Data Is Enforceable

Jones Day on

Court rules that a "John Doe" summons to obtain confidential client records from a law firm isn’t barred by attorney-client privilege. On May 15, 2019, a district court in the Western District of Texas held that the...more

Foodman CPAs & Advisors

El IRS está pendiente al Cripto

El Jefe de Investigación Criminal del IRS, Don Fort, declaró recientemente: "Es posible utilizar Bitcoin y otras Criptomonedas de la misma manera que las cuentas bancarias extranjeras para facilitar la evasión de impuestos"....more

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