Tax Evasion

News & Analysis as of

Owner of Professional Employer Organization Pleads Guilty to Employment Tax Charge

On Jan. 6, 2017, Janis Edwards, the owner of a professional employer organization, pleaded guilty to tax evasion arising from failing to pay over to the IRS between $3.5 million and $25 million in withholdings that her...more

New Tax Information Exchange Agreement Between the United States and Argentina

The governments of Argentina and the United States signed on December 23rd, 2016, a new tax information exchange agreement (“TIEA”). Jack Lew, U.S. Treasury Secretary, stated that the TIEA will allow for important...more

The High Cost of Being Noncompliant with the Internal Revenue Code

The IRS currently offers the following five programs for noncompliant taxpayers: (i) the Offshore Voluntary Disclosure Program (OVDP), (ii) Streamlined Domestic Offshore Procedures, (iii) Streamlined Foreign Offshore...more

"'Failure to Prevent': The Implications for Global Financial Institutions"

The U.K. government is set to introduce a new corporate criminal offence, based on the strict liability of the entity in question. It almost certainly will come into force in 2017, once the Criminal Finances Bill (Bill) is...more

"The New UK Corporate Offence of 'Failure to Prevent the Facilitation of Tax Evasion': Implications for Fund Managers and...

The U.K. government expands its crackdown on tax evaders and the persons who assist them, by targeting businesses who fail to prevent tax evasion....more

OCAC Publishes Report on Voluntary Disclosure Program

The Offshore Compliance Advisory Committee (OCAC) has published its report on the CRA’s Voluntary Disclosure Program, the first of several anticipated OCAC reports in furtherance of the OCAC’s mandate to provide advice to the...more

Expansion of US disclosure requirements will impact foreign investors – the future of money laundering and tax enforcement

The United States is turning its attention to activities by foreign investors who use US trusts, limited liability entities, and other investment structures to conceal the ownership of criminal proceeds or foreign tax...more

IRS on the Hunt for Bitcoin Users

Bitcoin is the most popular of the virtual currencies. In Notice 2014-21, the IRS advised that such currencies are not money, but property, for tax purposes. Two implications of this are that persons who use Bitcoins to...more

Corporate criminal liability risk increases for financial services

A proposed new UK law contains the largest expansion of UK corporate criminal liability since the Bribery Act 2010 and one of the most significant overhauls of money laundering and proceeds of crime legislation in the last...more

Your Daily Dose of Financial News

The IRS isn’t waiting around for virtual currency to gain wider acceptance. No, it’s more than happy to go after Bitcoin users who have sought to use the virtual currency as a means of evading taxes....more

Follow the money - the Criminal Finances Bill

The Criminal Finances Bill sets out measures to combat money laundering and tax evasion that will also affect corporate compliance requirements, particularly in the finance and professional services sectors....more

Criminal Finances Bill Proposes Some Intrusive & Impractical POCA Measures

On 25 October 2016, the Criminal Finances Bill 2016–2017 (the “Bill”) had its second reading in the House of Commons and passed without objection. In addition to containing the proposed new offence of failing to prevent tax...more

The Saga Ends With Ex-Tax Court Judge Pleading Guilty to Cheating on Her Taxes

As previously reported, former U.S. Tax Court judge Diane L. Kroupa and her now estranged husband, Robert E. Fackler, were indicted on charges of conspiracy to defraud the United States, tax evasion, making and subscribing a...more

Tax Evasion - Nowhere Left to Hide

Global tax evasion remains a major problem for governments around the world. At a time when virtually all of the governments from the world’s major economies seek additional revenue, the attractiveness to taxpayers of...more

Further expansion of corporate criminal liability

With the publication of the draft Criminal Finances Bill 2016-2017 on 13 October 2016, businesses have been put on notice of what stands to be the largest expansion of UK corporate criminal liability since the Bribery Act...more

Your Daily Dose of Financial News

Federal regulators unveiled a proposal yesterday that would push the country’s biggest banks and other “critical financial companies” to shore up cybersecurity protocols, to prevent hacks, and to have a recovery plan at the...more

Failure to Maintain Business Records Can Lead to Prosecution

A recent appellate court case out of New York (U.S. vs. Marinello) affirmed the conviction for tax evasion of a taxpayer for failing to maintain business records and timely file income tax returns. The facts of the case are...more

Tax Delinquencies to Jeopardize Contract Eligibility Under New Final Rule

On Friday, Sept. 30, 2016, the Department of Defense, the General Services Administration and the National Aeronautics and Space Administration issued a Final Rule aimed at blocking tax evaders and convicted felons from...more

Tax Delinquencies to Jeopardize Contract Eligibility Under New Final

On Friday, September 30, 2016, the Department of Defense, General Services Administration and National Aeronautics and Space Administration issued a Final Rule aimed at blocking tax evaders and convicted felons from receiving...more

Former Tax Court Judge Kroupa Is Back in the News

As reported in my April 2016 blog post, former U.S. Tax Court judge Diane Kroupa and her husband, Robert E. Fackler, were indicted on charges of conspiracy to defraud the United States, tax evasion, making and subscribing a...more

Proposed New UK Penalties Regime Precipitated by CRS

Many people will be familiar with the information gathering and reporting requirements the OECD’s Common Reporting Standard (“CRS”) places on financial institutions. The first exchanges of information between tax authorities...more

Criminal consequences of the use of leaked data by tax authorities

Leaks of confidential information are becoming more common. Businesses and individuals may face scrutiny by investigative agencies following leaks of information from third parties or by employees. Businesses in particular...more

Your daily dose of financial news - The Brief – 9.12.16

The past 2 years have been just short of disastrous for most hedge funds. But even without much to show in the form of results, the world’s biggest fund manager—Bridgewater Associates—has attracted $22.5 billion in investor...more

The Panama Papers - What the Fallout Means for U.S. Companies and Professionals [Video]

White Collar Defense/Internal Investigations Partner Peter D. Hardy discusses the financial implications of the Panama Papers leak on U.S. companies and professionals, the growing perception of the United States as a tax...more

Your daily dose of financial news - The Brief – 9.6.16

Dealbook gives us the story of Airgas, where founder Peter McCausland’s reticence to sell (despite serious shareholder pressure) resulted in a $5 billion windfall rather than the all-too-often result of a later sale for...more

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