5 Key Takeaways | 2024 Emerging Trends: Delaware Unclaimed Property VDA and Multistate Audits
The Presumption of Innocence Podcast: Episode 44 - A Recipe for Litigation: The Simmering Conflict Surrounding ERC Claims
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
FCPA Survival Guide: Step 1 - Self-Disclosure
Episode 316 -- DOJ Announces New Whistleblower Policy
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
The Presumption of Innocence Podcast: Episode 28 - Under the Microscope: Examining the Future of the ERC
Episode 289 -- Justice, Commerce and Treasury Issue Joint Notice on Voluntary Disclosure
What DAG Lisa Monaco's Speech Means for Compliance Programs
Torres Talks Trade Podcast- Episode 13- When Government Agencies Come Knocking
Torres Talks Trade Episode 11 on Sanctions and Export Enforcement Cases by DOJ
The Justice Insiders Podcast: The DOJ Wants You! - Part II: Voluntary Disclosures
Williams Mullen's Comeback Plan: Part I – State & Local Tax (SALT) Compliance During COVID-19: What to Do When You’re Behind
Anti-corruption & international risk developments
Podcast - Risk Management: Impact of Revised FCPA Policy on International Risk Management Programs
Podcast - Risk Management: Revised FCPA Corporate Enforcement Policy
FCPA Compliance Report-Episode 366 Jonathan Marks on performing and using a root cause analysis
This Week in FCPA-Episode 56
Everything Compliance-Episode 12
FCPA Pilot Program
In the wake of the COVID-19 pandemic, Congress passed the Employee Retention Tax Credit (“ERTC”) in an effort to help struggling businesses keep their employees on payroll throughout the pandemic. However, the Internal...more
OVERVIEW - Thousands of businesses struggling to stay afloat during the COVID-19 pandemic filed employee retention credit (ERC) claims in order to retain workers during a time of economic uncertainty. Initially, the rules and...more
The House Ways and Means Committee recently advanced a bill that gives businesses a proposed deadline of January 31, 2024 to file Employee Retention Credit (ERC) claims. This comes on the heels of recent announcements by the...more
In late 2023, the Internal Revenue Service (IRS) implemented three important initiatives that will impact employers who have filed, or intend to file, Employee Retention Credit (ERC) refund claims. This alert provides a brief...more
For some time, the IRS has targeted fraudulent employee retention credit (“ERC”) claims. More recently, on December 21, 2023, the IRS issued guidance on a new voluntary disclosure program (the “ERC-VDP”) that the agency...more
The Employee Retention Tax Credit (“ERTC”), under the CARES Act, is a refundable tax credit filed against a company’s payroll taxes. The ERTC was enacted to incentivize employers to maintain their employee base during the...more
By: Matthew E. Foreman, Esq., LL.M. and Samuel J. Brady On December 21, 2023, the IRS announced a new Voluntary Disclosure Program (the “Program”), allowing employers (both businesses and not-for-profits) who received the...more
The Internal Revenue Service (“IRS”) announced in IR News Release 2023-247 (December 21, 2023) its new Voluntary Disclosure Program (“ERC VDP”) that allows employers who may have received questionable Employee Retention...more
State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more
Federal case and after federal case continues to come out providing real-life examples of the pitfalls of filing a Streamlined Filing Compliance Procedure (“SFCP”) with the IRS when the facts suggest willfulness rather than...more
Taxpayers who employ workers have obligations under federal law to withhold and remit federal employment taxes to the IRS. In addition to this withholding and payment requirement, federal law also imposes certain reporting...more
On February 15, 2022, the IRS announced that IRS Form 14457, Voluntary Disclosure Practice Preclearance Request and Application, and the accompanying instructions to the form had been revised. Because the revisions provide...more
The concept of “willfulness” is an important one in the FBAR civil penalty context. Indeed, a taxpayer’s willful failure to file a timely and accurate FBAR may result in significant penalties: the higher of 50-percent of...more
For one reason or another, I had several calls last year with attorneys and others regarding IRS Streamlined Filing Compliance Procedure submissions gone wrong. In most cases, it was evident that the tax professional had...more
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
This morning, I woke up to news in the Wall Street Journal that indicated that the United States and the Republic of Malta had entered into a Competent Authority Agreement (“CAA”). Generally, this news would not have caught...more
United States citizens and residents[i] are subject to federal income tax on their worldwide income. For example, even if a United States citizen permanently relocates to a foreign country, he or she will generally continue...more
Cryptocurrency is more accessible than ever before. Banks are continuing to both implement procedures for and, in some cases, develop their own cryptocurrencies. Paypal allows users in the U.S. to buy, sell and hold select...more
This article is the second of a three-part series regarding the State and Local Tax consequences of doing business in multiple states. This article will discuss Voluntary Disclosure, Part 1 discussed Nexus and Part 3 will...more
Tax partners Stephanie Lipinski Galland and Kyle Wingfield summarize what you can do if you have not filed your state and local taxes or if you are unable to pay your tax bills due to the COVID-19 pandemic. Topics include...more
There was an IRS termination of the Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018. On November 20, 2018, following the OVDP notice of termination, there was a release of a Memorandum announcing the...more
Virtual currency transactions are now a prime focus of Internal Revenue Service (IRS) scrutiny. The IRS has numerous information-gathering tools to enforce its taxing power, including summons, artificial intelligence, data...more
IRS holds information that is sourced from the FATCA reports submitted by Foreign Financial Institutions (FFI) (on Form 8966 - FATCA Report) and by Individual US Taxpayers that have reporting obligations via Form 8938...more
On September 28, 2018, the IRS closed the Offshore Voluntary Disclosure Program (2014 OVDP). The 2014 OVDP (and prior 2011 and 2009 programs) had the purpose of providing Taxpayers that WILLFULLY failed to report foreign...more
Following the termination last fall of its immensely successful Offshore Voluntary Disclosure Program (OVDP), the Internal Revenue Service (IRS) has announced a new regime to govern all voluntary disclosures regarding tax...more