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Government Investigations Internal Revenue Service

Polsinelli

Real or Ruse? IRS’s New Settlement Initiative for Syndicated Conservation Easements

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The Internal Revenue Service (IRS) recently announced a new settlement initiative for Syndicated Conservation Easements (SCEs) that are currently under audit and have not reached the Tax Court. This new settlement initiative...more

Arnall Golden Gregory LLP

Q&A With Allison Raley: Defending Against Government Investigations

Q: What are the primary areas of focus in your practice related to government investigations? A: My practice primarily focuses on defense against enforcement actions brought by regulatory bodies such as the Office of Foreign...more

Polsinelli

CPA gets 25 years for Promoting Conservation Easement Deductions

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Judge Batten, Chief United States District Judge for the Northern District of Georgia, handed down lengthy sentences in the first-of-its-kind criminal trial related to syndicated conservation easements (“SCEs”). On January...more

Association of Certified E-Discovery...

Does FRE 502(d) Allow a Party to Shift the Privilege Burden?

[Editor’s Note: This article has been republished with permission. It was originally published December 20, 2023 on the eDiscovery Assistant Blog] In Episode 127, on the ACEDS and eDiscovery Assistant #CaseoftheWeek, Kelly...more

Polsinelli

Slogans and Insults: Fisher Defendants Respond to the Government’s Novel Conservation Easement Case

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Last week, the first federal criminal trial related to syndicated conservation easement (“SCE”) deals began with impaneling the jury and opening statements. Each of the Fisher defendants on trial, Jack Fisher, James Sinnott,...more

Polsinelli

Government Asserts the Defendants Lied and Cheated the IRS out of over $1.3 Billion: The Government’s Opening Statement of the...

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The first criminal prosecution of syndicated conservation easement promoters began on July 18, 2023, with the government laying out its case against defendants Jack Fisher, James Sinnott, and Clayton Weibel.  A Department of...more

Kohrman Jackson & Krantz LLP

Move Over TikTok, the Tax Man May Be Snooping on You, Too

In a rare unanimous opinion, the U.S. Supreme Court recently confirmed that existing law allows the IRS to probe your bank records, without ever notifying you. Under the applicable statute, the Court concluded the IRS is not...more

Polsinelli

Appraiser Pleads Guilty to Fraud in Syndicated Conservation Easement Case

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Polsinelli’s Government Investigations and Tax attorneys continue to follow the well-known Fisher case, the Department of Justice’s ("DOJ") first criminal indictment related to syndicated conservation easements. Walter...more

Polsinelli

New York Alleges Trump Procured Inflated Appraisals for Conservation Easements

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On September 21, 2022, the New York State Attorney General Tish James filed a civil lawsuit against former President Donald Trump and the Trump organization alleging fraud and misrepresentation. The Complaint described a...more

Polsinelli

The DOJ and IRS Focus Enforcement on Syndicated Conservation Easements

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Earlier this year, the Department of Justice filed the first criminal indictment of promoters, appraisers and accountants connected to an alleged scheme to create syndicated conservation easements. The move followed increased...more

Freeman Law

Criminal Tax Statutes of Limitations and Suspensions: 18 U.S.C. § 3292 and the Fifth Circuit’s Decision in Pursley

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In civil and in criminal cases, the Government must generally act within a certain prescribed time to take action against taxpayers. In legal parlance, this period of time is known as the “statute of limitations.” The...more

Foodman CPAs & Advisors

How the IRS Uses Social Media to Find Crypto Tax Cheats

Does your Twitter, Reddit, Facebook, Instagram or other social media feed feature photos of your new sports car, boat, fabulous vacation or the beach house that you bought with your crypto gains? Do you also report a low...more

Troutman Pepper

Final Section 162(f) Regulations Set Forth Deductibility Rules for Payments Involving Government Investigations

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Background - Sections 162(f) and 6050X changed the requirements for taxpayers to deduct amounts paid to the government or at its direction under court-ordered judgments, settlement agreements, non-prosecution agreements,...more

WilmerHale

Final Section 162(f) Regulations Liberalize Opportunities to Deduct Disgorgement and Other Payments Made in Government...

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On January 12, 2021, the Internal Revenue Service (IRS) and the Treasury Department released final regulations governing the deductibility of certain fines, penalties and other amounts paid to, or at the direction of, a...more

Freeman Law

The FBAR (Report of Foreign Bank and Financial Accounts): Everything You Need to Know

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What is the Report of Foreign Bank and Financial Accounts (FBAR)? Congress enacted the statutory basis for the requirement to report foreign bank and financial accounts in 1970 as part of the “Currency and Foreign...more

Foodman CPAs & Advisors

¿Sabías que el IRS está Involucrado en la Investigación y el Enjuiciamiento del Soborno?

En 1977, los Estados Unidos promulgó la Ley de Prácticas Corruptas en el Extranjero (FCPA).  El FCPA prohíbe una oferta, pago, promesa o la autorización de un pago de dinero o cualquier cosa de valor (también conocido como...more

Foodman CPAs & Advisors

Did you know that the IRS is Involved with Investigating and Prosecuting Bribery?

In 1977, the United States enacted the Foreign Corrupt Practices Act (FCPA).  The FCPA prohibits an offer, payment, promise or the authorization of a payment of money or anything of value (a/k/a bribery) to a foreign official...more

Arnall Golden Gregory LLP

COVID Investigations Raise Questions About Oversight and Enforcement Before the Pandemic

On September 3, 2020, Special Agents of the Federal Bureau of Investigation, Department of Health and Human Services Office of Inspector General, and the Internal Revenue Service, along with investigators from the...more

Oberheiden P.C.

For Business Owners, Allegations of Paycheck Protection Program (PPP) Loan Fraud Can Lead to Steep Federal Penalties

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While there has been a lot of controversy in the media surrounding the Paycheck Protection Program (PPP), there is no question that the program has served as an invaluable lifeline to many small and medium-sized businesses...more

Jones Day

IRS Summons for Law Firm Client Data Is Enforceable

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Court rules that a "John Doe" summons to obtain confidential client records from a law firm isn’t barred by attorney-client privilege. On May 15, 2019, a district court in the Western District of Texas held that the...more

Coblentz Patch Duffy & Bass

Congress Increases Scrutiny of Syndicated Conservation Easements

Senate Finance Committee launches investigation, while anti-syndication bill is introduced in the House and Senate....more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Call an ERISA attorney when you get the government’s call

When you get pulled over by the police while driving, the best way to handle is to be pleasant and not be argumentative. You listen to the officer as to why he pulled over. Being belligerent and non-cooperative will only lead...more

Foodman CPAs & Advisors

Government Agencies are spending money to track down Virtual Currency

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Government agencies apparently believe that expertise from blockchain analytic firms is required to assist with investigating illicit activities such as tax evasion, money laundering, terrorist financing, and drug markets. ...more

Ballard Spahr LLP

Civil Forfeiture Enforcement Under Fire – Part I

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Forfeiture actions by Internal Revenue Service Criminal Investigation (IRS CI) based on alleged structuring activity have come under fire, yet again. Specifically, the Treasury Inspector General for Tax Administration (TIGTA)...more

Robinson+Cole Data Privacy + Security Insider

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

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