News & Analysis as of

Tax Evasion Internal Revenue Code (IRC)

Holland & Knight LLP

Treasury Department Confirms Suspension of U.S.-Russia Income Tax Treaty

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The U.S. Department of the Treasury on June 17, 2024, confirmed it had formally notified Russia about the suspension of the Convention between the United States of America and the Russian Federation for the Avoidance of...more

Allen Barron, Inc.

IRS Warns High Income US Taxpayers and Millionaire Non-Filers

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The IRS has recently issued an ominous notice (#IR-2023-126) in which the IRS warns high income US taxpayers and millionaire non-filers that the IRS is targeting them to conduct audits, identify and collect undeclared income...more

Lerch, Early & Brewer

Tenth Circuit Affirms Deficiencies, Penalties for Offshore Income

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Harrington v. Commissioner - In Harrington v. Commissioner of Internal Revenue, George S. Harrington (Harrington) challenged tax deficiencies and fraud penalties assessed for tax years 2005 through 2010. Originally...more

Freeman Law

Section 6751(b) Penalty Approval Circuit Split

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Eleventh Circuit Sides with Ninth Circuit on Section 6751(b) Circuit Split - Introduction: Section 6751(b) and the Timing of Supervisory Approval of a Penalty - The Eleventh Circuit’s decision in Kroner v. Commissioner,...more

Foodman CPAs & Advisors

IRS Warns Taxpayers Against Tax Avoidance Strategies

The IRS wrapped its 2022 Dirty Dozen scams list urging taxpayers to watch out for and avoid being misled by tax avoidance strategies. Making the 2022 List are Cryptocurrency, non-filing, abusive syndicated conservation...more

Freeman Law

IRS Criminal Investigation’s Top Ten Cases of 2021

Freeman Law on

Many (if not most) people and organizations approach a new year by setting new goals or implementing changes. This exercise, however, requires a reflection on the previous year’s events, successes, and failures. And...more

Freeman Law

26 U.S.C. § 6672 – Failure to Collect and Pay Over Tax, or Attempt to Evade or Defeat Tax

Freeman Law on

Also Referred to as Internal Revenue Code Section 6672; I.R.C. § 6672; Section 6672; Trust Fund Recovery Penalty - Background. In certain instances, the Internal Revenue Code (the “Code”) requires persons to withhold...more

Freeman Law

The IRS’s Renewed Focus on Abusive Trust Arrangements

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Taxpayers have long utilized trust arrangements for the transfer of wealth to beneficiaries or for the protection of assets from creditors.  Generally, there is nothing nefarious about these types of arrangements.  Rather,...more

Gray Reed

Non-Willful FBAR Penalties Will be Much Higher in the Fifth Circuit

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On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account...more

Freeman Law

“Extreme Personal Hardship” Doesn’t Excuse Trust Fund Recovery Penalties

Freeman Law on

Trust Fund Recovery Penalties (or TFRPs) refer to the tax penalties assessed against the responsible person(s) of a business (e.g., directors, officers, etc.) that failed to collect, account for, or pay over taxes on behalf...more

Oberheiden P.C.

Eleven of the IRS's Enforcement Priorities During the 2021 Tax Season

Oberheiden P.C. on

It is tax season once again. While the Internal Revenue Service (IRS) has extended this year’s filing deadline to May 17, 2021 for individuals, businesses must still file by April 15, and all U.S. taxpayers must ensure that...more

Morgan Lewis

Sovereign Wealth Funds Update: Tax Aspects of Private Fund Investments: Selected US, EU, and UK Considerations in the Current...

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Despite the market disruption caused by the COVID-19 pandemic, sovereign wealth funds continued to make significant capital commitments to private funds during 2020, on a global basis. As the world emerges from the pandemic,...more

Freeman Law

Can You Go To Jail for Failing to Disclose Virtual Currency on a Tax Return or as Part of an Offer for a Collection Alternative?

Freeman Law on

Virtual currency, such as Bitcoin, continues to be a topic of interest for the IRS. Indeed, for the 2019 tax year, the IRS added for the first time a unique question to Schedule 1, Additional Income and Adjustments to...more

McDermott Will & Emery

Weekly IRS Roundup February 17 – 21, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 17 – 21, 2020. February 18, 2020: The IRS issued a revenue ruling providing various...more

Foodman CPAs & Advisors

Indirect linkages to Tax Havens

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The U.S. income tax system is based on the idea of voluntary taxpayer compliance. It is the taxpayer’s responsibility to report all reportable worldwide income. Some people attempt to evade paying taxes by failing to report...more

Akin Gump Strauss Hauer & Feld LLP

U.S. Withholding on Synthetic Trades over U.S. Equities – Additional Delay of Full Implementation until 2021 (Notice 2018-72)

• The broader application of Section 871(m) has been delayed further until January 1, 2021 and, as a result, investment funds with non-U.S. feeders or investors up the chain should generally expect to incur U.S. withholding...more

Jones Day

U.S. Supreme Court: Government Went Too Far in Tax Obstruction Prosecution

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The U.S. Supreme Court today barred the government from prosecuting taxpayers for obstructing the administration of the Internal Revenue Code, unless it can show they acted in response to a pending or reasonably foreseeable...more

Morrison & Foerster LLP

Cryptocurrency Exchanges - the New Front of the IRS War on Tax Evasion?

Morrison & Foerster LLP on

On November 29, 2017, the U.S. District Court for the Northern District of California dealt a partial blow to the U.S. Department of Justice and the IRS in connection with their collective efforts to enforce an expansive and...more

Akin Gump Strauss Hauer & Feld LLP

U.S. Withholding on Synthetic Trades over U.S. Equities—Further Delay of Full Implementation Until 2019 (Notice 2017-42)

In response to perceived abuses in taxpayers’ use of swaps and other derivative transactions (e.g., options, futures or forwards) to avoid withholding tax on U.S. source dividends, Congress added Section 871(m) to the...more

Bowditch & Dewey

IRS and States Crack Down on POS Systems: Zapper Software

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A good point of sale (“POS”) system is critical for any business engaged in sales to the public and having one in place goes a long way to ensuring that revenue and profits are being reported properly to federal, state and...more

Ballard Spahr LLP

2016 Year End Review: Virtual Currency: DOJ and IRS Broadly Seek Virtual Currency Account User Information

Ballard Spahr LLP on

Under Internal Revenue Code section 7609(f), the IRS may issue a “John Doe” administrative summons to discover the identities of unknown taxpayers. A “John Doe” summons can be a powerful enforcement tool because it allows the...more

Akerman LLP

Treasury Department Extends Filing Requirements to Foreign-Owned Domestic Disregarded Entities

Akerman LLP on

On May 10, 2016, the Treasury Department issued proposed regulations (the Proposed Regulations) which enable the Internal Revenue Service (IRS) to collect certain information about domestic disregarded entities with a single...more

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