News & Analysis as of

Tax Evasion Internal Revenue Service

Will Supreme Court Narrow The Broadest Tax Crime?

by McGuireWoods LLP on

In the October 2017 term, the Supreme Court will take up its first criminal tax case in almost a decade, Marinello v. United States. At issue is a longstanding circuit split about a mainstay of the federal government’s...more

"Money" Mayweather’s $22 Million Tax Problem

by Moskowitz LLP on

Floyd "Money" Mayweather certainly lives up to his nickname – the undefeated boxer is expected to cash in as much as $350 million for his recent win against Irish UFC fighter Conor McGregor....more

Tax Return Preparer Sentenced to 27 Months for Tax Evasion

by Moskowitz LLP on

Tax evasion carries severe penalties, even in cases in which no one else has been defrauded. The facts - From 2005 through 2011, Semere Tsehaye owned more than 20 Instant Tax Service (ITS) franchises in Illinois, Kansas...more

San Antonio Businessman Sentenced To Four Years in Prison for Defrauding Personal Injury Clients, the Bankruptcy court, and the...

by Moskowitz LLP on

From 2009 through 2014, Elpidio Gongora (aka “Pete Gongora”), operated a number of personal injury law offices in Texas, Arkansas and New Mexico. The lawyers in these firms apparently obtained settlements on behalf of their...more

18 Months in Prison for Cashing Client Checks and Not Reporting the Income to the IRS

by Moskowitz LLP on

A man who provided landscaping and snowplowing services to residential and commercial customers in Hartford, Connecticut is serving 18 months in jail for underreporting his income....more

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

IRS and States Crack Down on POS Systems: Zapper Software

by Bowditch & Dewey on

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

Cumplimiento Fiscal Internacional

by Foodman CPAs & Advisors on

Detectar, disuadir y responder al incumplimiento internacional son desafíos clave que enfrentan las autoridades tributarias de todo el mundo. El incumplimiento fiscal internacional es un problema significativo reconocido por...more

Unfiled Tax Returns: What Do You Do? (Part 2)

by McNair Law Firm, P.A. on

The United States has a voluntary income tax reporting system. U.S. citizens, permanent residents, and businesses here must annually file income tax returns with the IRS, reporting their “worldwide income”, deductions, and...more

No Rest For The Weary: Offshore Tax Evasion Crackdown Continues With Flurry Of Mid-Summer Activity

by Fox Rothschild LLP on

Dashing any thought that they were taking a hiatus from investigating and prosecuting taxpayers with secret offshore bank accounts and the bankers that helped them, the Justice Department and Internal Revenue Service have...more

The Complete Saga of Former U.S. Tax Court Judge Diane L. Kroupa is Now Finally Concluded

by Garvey Schubert Barer on

As reported in my April 7, 2016, October 3, 2016 and October 27, 2016 blog posts, former U.S. Tax Court Judge Diane L. Kroupa and her then husband, Robert E. Fackler, were indicted on charges of tax fraud. Specifically, they...more

Three More Countries Will Now Provide IRS Information On Bank Interest Paid To Nonresident Aliens

by Fox Rothschild LLP on

The IRS recently released Revenue Procedure 2017-31 which adds Belgium, Columbia and Portugal to the list of participates in the automatic exchange of information on bank interest paid to nonresident alien individuals for...more

Challenge and Counter-Proposal

by Moskowitz LLP on

In Part I, we outlined the scope of the November 2016 summons served on Coinbase to identify its users and their transaction activity and the IRS’ justification for requesting this data under 26 U.S. Code § 7602. Section 7602...more

Debit cards, Offshore Funds and a John Doe Summons

by Foodman CPAs & Advisors on

IRS remains committed to its priority efforts to stop offshore tax evasion wherever it occurs. It pursues cases in all jurisdictions of the world. Over the years, numerous individuals have been identified as evading US...more

On the Eve of Tax Day, Justice Department Warns That Tax Evaders Will Face Prison Time

by Fox Rothschild LLP on

With only four days remaining until “Tax Day,” the Justice Department’s well-publicized campaign to deter potential tax evaders continues with more stern warnings to taxpayers. In a bleak press release entitled “With the...more

As Tax Day Approaches, Justice Department and IRS Turn Up Heat on Potential Tax Cheats

by Fox Rothschild LLP on

With less than two weeks until the April 18 deadline for filing individual federal income tax returns, the Justice Department and Internal Revenue Service are issuing stern warnings to potential tax cheats. Today the U.S....more

IRS Files Petition to Enforce Summons Issued to Virtual Currency Company

The Internal Revenue Service (IRS) obtained authorization from a California federal court last November to serve a John Doe summons on the virtual currency firm Coinbase in order to obtain customer information to determine...more

Tax Update, Volume 2017, Issue 2

by Pepper Hamilton LLP on

THE NEW REGULATIONS EXPAND THE FILING REQUIREMENTS FOR FORM 5472 TO INCLUDE DISREGARDED ENTITIES WITH FOREIGN OWNERS WHEN THERE ARE CERTAIN REPORTABLE TRANSACTIONS. If a non-U.S. person (individual or corporation)...more

Combatting Foreign Tax Evasion With New Filing Requirements for Foreign-Owned Disregarded Entities: Tax Update, Volume 2017, Issue...

by Pepper Hamilton LLP on

If a non-U.S. person (individual or corporation) owns 100 percent of the stock of a U.S. corporate subsidiary, the subsidiary needs to obtain an employer identification number (EIN) and maintain adequate books and records to...more

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

by 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

Bitcoin and the IRS - The Battle Continues

Dispute is heating up over IRS’s attempts to get personal information about users of Bitcoin and other virtual currencies. Last November, the Internal Revenue Service (“IRS”) filed a petition in the United States...more

The High Cost of Being Noncompliant with the Internal Revenue Code

by Holland & Knight LLP on

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

IRS on the Hunt for Bitcoin Users

by Charles (Chuck) Rubin on

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

Your Daily Dose of Financial News

by Robins Kaplan LLP on

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

Tax Evasion - Nowhere Left to Hide

by K&L Gates LLP on

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

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Cybersecurity

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