What is the IRS Offshore Voluntary Disclosure Program and who is it designed to help? What are the guidelines for voluntary disclosure to the IRS and who is eligible to apply? The IRS Offshore Voluntary Disclosure...more
Following the 2021 report, the South African Parliament adopted legislative changes in the General Laws (Anti-Money Laundering and Combating Terrorism Financing) Amendment Act, 2022 (the GLA Act) to give effect to the...more
As we have blogged repeatedly, there is a close nexus between money laundering and tax crimes. The frequent connection between the two sets of offenses – and the potentially related methods of combatting them – is a topic...more
El Pleno de la Suprema Corte de Justicia de la Nación (SCJN) de México, el 24 de noviembre de 2022, resolvió la Acción de Inconstitucionalidad 130/2019 y su acumulada 136/2019 en la que se determinó mantener la prisión...more
The rising incidence of financial crime continues to haunt financial institutions globally. As per a recent industry report, more SARs (suspicious activity reports) were filed by ~80% of the firms in 2021. COVID-19 pandemic...more
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
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
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
In 2017, following the Panama Papers and Paradise Papers data leaks, the Organization for Economic Co-operation and Development (OECD) issued a “call to action” for countries to do more to tackle enablers of tax crimes. ...more
In a previous blog, I provided an overview of Section 3582(c) with respect to the modification of prison terms. In addition, I looked at two recent cases (United States v. Higa [Hawaii] & United States v. McGrath [Ohio]) that...more
Matt Borges was an up-and-comer in Republican politics. He was a former leader of the Ohio Republican Party, and in 2016, he was a candidate to become head of the Republican National Committee. ...more
The list of state and local tax crimes seems endless: from fraud to operating a retail location without a sales tax permit. Shawn Cleveland and Robb Adkins from the BakerHostetler white collar litigation team join Matt...more
In 2018, the Organization for Economic Co-operation and Development (OECD) issued a “call to action” for countries to do more to tackle enablers of tax crimes. ...more
Third Circuit Holds False Claims Act Relator Lacks Standing and Right to Intervene in Related Criminal Case - In a matter of first impression, the Third Circuit held last week that a relator who filed an action under the...more
The Mexican Congress approved with some adjustments the Tax Bill presented by the President on September 8, 2019, that included a proposal of Decree through which various provisions of the Income Tax Law, the Value Added Tax...more
This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including a review of the first year of GDPR enforcement, analysis of...more
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
Earlier this month, the five leaders of the Joint Chiefs of Global Tax Enforcement (known as the “J5”) met in Washington to commemorate the one-year anniversary of the formation of the J5 organization and to announce their...more
With April 15 just around the corner, the Justice Department’s Tax Division has issued its annual public warning to would-be tax cheats. It is no secret that the Justice Department and Internal Revenue Service significantly...more
On November 11, 2018, the IRS released its Criminal Investigation Annual Report as it begins its 2019 fiscal year and its 100th anniversary as a law enforcement agency. IRS-Criminal Investigation (IRS-CI) is a federal agency...more
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
Shakespeare’s observation that the “past is prologue” certainly applies to corporate criminal liability in the UK and France, as these jurisdictions embrace with gusto corporate prosecutions akin to those pursued in the US...more
The IRS-Criminal Investigation Unit (IRS-CI) is the Criminal Law Enforcement Arm of the IRS. Its conviction rate of over 90% is one of the highest in federal law enforcement. Those convicted pay taxes, penalties and...more
Due to the Foreign Account Tax Compliance Act (FATCA) and the work of IRS special agents, international tax transparency is here. There is virtually nowhere to hide. On 1/18/17, the Department of Justice (DOJ) reported that...more
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