Tax Evasion Audits

News & Analysis as of

Focus on Tax Controversy and Litigation - United States Tax Court Invalidated Treasury Regulation § 1.482-7(d)(2)

In addition to the discussion of the Tax Court’s decision in Altera, this month’s issue features articles regarding Notice 2015-47 “Basket Options” and Notice 2015-48 “Basket Contracts”, the Federal Circuit Court of Appeals...more

Check Cashing, Tax Evasion, Structuring and Asset Forfeiture; The Making of a Bad Day

The following fact pattern should is representative of a tax evasion and structuring case. A taxpayer receives checks in the ordinary course of business from customers. Some of those checks are deposited into the business...more

INTERPOL and the tax man

A reader recently sent in the following questions: Can you tell me would the IRS issue a diffusion notice in a civil tax audit involving offshore banking? Would Interpol even accept a diffusion notice on a non criminal...more

Upcoming Nationwide Transfer Pricing Investigation Against Outbound Service Fee And Royalty Payments

On 29 July 2014, the China State Administration of Taxation (SAT) released an internal notice to the China tax authorities at the provincial levels, in the name of "Notice on Antiavoidance Investigation against Large Amount...more

Recent Sentences for Federal Tax Crimes in 2014 – Part 2

On Friday, we posted a review here of sentences imposed on defendants in 2014 for Foreign Bank Account, Tax Evasion, and Employment Tax crimes. In this post, we review sentences imposed on defendants in cases involving False...more

“Breaking Bad” And Tax Evasion

I love the TV Series “Breaking Bad” on AMC. In a nutshell, it is about a tough luck high school chemistry teacher named Walter White who turns into a major drug dealer and murderer. ...more

Offshore Banks, Required Records and Secret Funds Transfers: a Receipe for Disaster

Recently, two Israeli banks are reported to have agreed to cooperate in criminal tax investigations being conducted by the Criminal Tax Division of the U.S. Department of Justice. The specific actions allegedly involve a...more

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