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Tax Criminal Law

Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.

New Tax Law Changes Deductibility of Government Settlement Payments in False Claims Act, SEC, FINRA, and Other Types of Cases

by Foley & Lardner LLP on

The new tax law changed the deductibility of settlements with government agencies in some circumstances thereby increasing the cost to companies to settle these cases. The deduction arose from the section in the Internal...more

IRS-Criminal Investigation Ramps Up Scrutiny Of Cryptocurrency Transactions

by Fox Rothschild LLP on

The Internal Revenue Service has assembled a specialized team of criminal investigators to build criminal tax evasion cases involving users of Bitcoin and other cryptocurrencies, according to a Bloomberg article entitled “IRS...more

Internet Gambling, Cryptocurrency and IRS Enforcement

by Sanford Millar on

Could Internet Gambling Sites be one of their targets? There are numerous on-line interactive casinos that accept cryptocurrency as a medium of funding player accounts. The use of cryptocurrency presents a new enforcement...more

DOJ Announces $3.7 Billion in 2017 FCA Recoveries

by Morgan Lewis on

DOJ highlights healthcare, housing and mortgage, and procurement fraud as largest areas of recovery; impending changes under the new tax legislation could limit tax deductions for False Claims Act payments....more

Businesses face unlimited fines for failure to prevent facilitation of tax evasion

by Womble Bond Dickinson on

Introduction - As part of a global crackdown on tax evasion, the Criminal Finances Act 2017 (the Act) introduced a new offence. From 30 September 2017, an organisation commits a criminal offence if an employee or...more

New Tax Bill Will Rewrite Rules for Deducting Disgorgement Payments to SEC

by Jones Day on

U.S. tax reform will mean new rules for deducting fines, penalties, and other amounts, including disgorgement, paid to the Securities and Exchange Commission ("SEC"). Currently, Internal Revenue Code section 162(f)...more

More Data Added To Paradise Papers Offshore Leaks Database

by Fox Rothschild LLP on

Yesterday the International Consortium of Investigative Journalists released information from the corporate registries of four more tax havens that were included in the Paradise Papers investigation: Barbados, the Bahamas,...more

This Week in FCPA-Episode 80, The Last Jedi Edition

by Thomas Fox on

Jay and I return for a wide-ranging discussion on some of the top compliance- and ethics-related stories of the week, including: 1. There are several FCPA 40th anniversary pieces going up these days. The FCPA Blog is looking...more

Corporate Law & Governance Update - December 2017

by McDermott Will & Emery on

Unprecedented 2018 Board Challenges - The health system board should be prepared to address an extraordinary number of significant, enterprise-level challenges that are expected to arise in 2018. These challenges will...more

France Announces Its First Deferred Prosecution Agreement

In a move that could signal a new phase of government enforcement in France, on November 27, 2017, French authorities published a Convention judiciaire d’intérêt public (CJIP) with HSBC Private Bank Suisse SA (HSBC PB), the...more

DOJ Announces Major New Shift in Criminal Sentencing in Offshore Tax Matters

At the 34th Annual National Institute on Criminal Tax Fraud in Las Vegas yesterday afternoon, Mark Daly, DOJ Tax Division Senior Litigation Counsel announced a major new shift in how the Department of Justice plans to argue...more

U.S. Court Orders Coinbase to Share Information about Account Holders with the IRS but Limits to Transactions over $20,000

A U.S. federal district court judge on Tuesday, November 29 ordered Coinbase Inc., the largest cryptocurrency exchange and storage platform in the world, to provide information about certain of its account holders to the U.S....more

Coinbase to turn over information to IRS. What does it mean for the bitcoin day trader?

by Sanford Millar on

On December 6, 2016 the Department of Justice (DOJ) served a “John Doe” summons to Coinbase, a San Francisco based exchange of cryptocurrency, to produce records of accounts held by U.S. taxpayers for the period of 2013...more

Facilitating tax evasion: how to avoid being unwittingly caught by the Criminal Finances Act 2017

by White & Case LLP on

The Criminal Finances Act 2017 came into force on 30th September 2017. It has introduced a new corporate criminal offence of failing to prevent tax evasion. This new offence is aimed at companies who have failed to put in...more

What If You Are Ineligible For The Offshore Voluntary Disclosure Program? Attorney Proffers versus Quiet Disclosures

by Sanford Millar on

Since the beginning of the current Offshore Voluntary Disclosure Programs (OVDP) in 2009 tens of thousands of U.S. taxpayers have come forward to report previously undisclosed foreign financial accounts. The addition of the...more

California Card Club Plagued By Allegations Of Criminal Activity Fined $8 Million For AML Violations

by Fox Rothschild LLP on

Today the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced that it had fined a California card club, Artichoke Joe’s Casino, $8 million for numerous willful violations of the Bank Secrecy Act...more

On Eve Of “Paradise Papers” Release, At-Risk Individuals Should Consider Immediate Action To Mitigate Potential For Criminal...

by Fox Rothschild LLP on

Tomorrow morning (November 17) the International Consortium of Investigative Journalists (ICIJ) is set to release publicly the first set of comprehensive data from the recent “Paradise Papers” leak. The initial data will...more

UK Tax Round Up - October 2017

by Proskauer Rose LLP on

UK Tax News and Developments - Government White Paper on Customs Bill - On 9 October, the Government published a White Paper setting out its approach to the introduction of a new customs and VAT regime after the UK...more

Criminal Finances Act 2017 – New Criminal Offence Requires Preventive Procedures

by McDermott Will & Emery on

The UK Criminal Finances Act 2017 recently introduced a new corporate offence of failure to prevent the facilitation of tax evasion. Under the new law, a corporate body or partnership may be criminally liable if it fails...more

Financial Services Quarterly Report - Third Quarter 2017: Global Update: UK Criminal Finance Act 2017: Immediate Considerations...

by Dechert LLP on

UK asset managers, non-UK asset managers carrying on business in the UK and the funds they manage are within the scope of the new corporate criminal offences of failing to prevent the facilitation of tax evasion. As the new...more

You are Contacted by an IRS Criminal Investigator: What Do You Do? Defending an IRS Criminal Investigation (Part 11)

by McNair Law Firm, P.A. on

The IRS investigates criminal violations of federal tax laws, including tax evasion, tax fraud, and not filing tax returns. Many people do not realize that simply not filing a tax return when it is due is a crime under...more

September 2017: An Update on UK Tax Disputes Including the New UK Corporate Criminal Offense: What Is It and What Should You Do...

Across the world, tax authorities are becoming more aggressive and have sharpened their focus on corporates and multinationals. As a result, tax audits, investigations and disputes have increased significantly, both at the...more

Second Circuit Finds Death Extinguishes Trial Convictions and Related Restitution Order – But Tax Offenses and Bail Forfeiture...

In 2010, a federal jury in the Eastern District of New York convicted body-armor tycoon David H. Brooks of multiple counts of conspiracy, insider trading, fraud, and obstruction of justice for his role in a $200 million...more

Out of Compliance Taxpayers: Beware of new IRS-Programs!

by Foodman CPAs & Advisors on

The IRS-Criminal Investigation Unit (IRS-CI) is the Criminal Law Enforcement Arm of the IRS. Its conviction rate of over 90% is one of the highest in federal law enforcement. Those convicted pay taxes, penalties and...more

UK Tax Round Up - September 2017

by Proskauer Rose LLP on

UK Tax News and Developments - Finance (No 2) Bill 2017 - The second Finance Bill of 2017, known as Finance (No 2) Bill 2017, has now been published. As expected, this contains most of the provisions which were dropped from...more

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