News & Analysis as of

Income Taxes › Department of Justice (DOJ)

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Cadwalader, Wickersham & Taft LLP

Crypto: Give Unto Caesar What Is Caesar’s

Cadwalader, Wickersham & Taft LLP on

Earlier this year the U.S. Department of Justice (“DOJ”) brought USA v. Ahlgren, its first crypto case with tax evasion allegations unrelated to another crime, demonstrating the DOJ’s willingness to pursue stand-alone crypto...more

Pillsbury Winthrop Shaw Pittman LLP

Don’t Forget to File (Accurately): 2024 Brings Heightened IRS and DOJ Focus on Non-Filers and Digital Assets

Pillsbury Winthrop Shaw Pittman LLP on

The IRS has increased funding for collection and enforcement, with a stated focus on high income non-filers and digital assets (among other areas). The DOJ has also emphasized a focus on digital assets, and the Department...more

BakerHostetler

No Further Warnings - Prosecutors Bring First Pure Legal Digital Asset Tax Indictment; More Criminal Cases to Come

BakerHostetler on

After years of explicitly warning taxpayers that failing to report or underreporting income from transactions involving digital assets would lead to criminal charges, federal prosecutors are now beginning to follow through on...more

Gray Reed

The IRS is Attacking Abusive Trust Arrangements

Gray Reed on

Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more

McDermott Will & Emery

Can the Government Sue for Tax Debts Outside IRC Procedures?

McDermott Will & Emery on

On June 1, 2023, in United States v. Liberty Global, Inc.[1], the US District Court for the District of Colorado held that the US Department of Justice (DOJ) can assert and seek judgment for federal income tax deficiencies...more

Miller Canfield

High-Profile Case Highlights Government's Common Law Right to Pursue Tax Deficiencies in Court

Miller Canfield on

A federal district court ruled in a high-profile case that the Justice Department may rely on common law rather than the statutory notice of tax deficiency procedure in the Internal Revenue Code to assert a federal income tax...more

BakerHostetler

New Crypto Payment and Web3 Products Launch; UK Seeks Input on DeFi Taxation; OFAC Fines Crypto Exchange; SEC, DOJ, CFTC Continue...

BakerHostetler on

Multiple Financial Services Firms Announce New Crypto Products - A major U.S. financial services firm recently launched its Crypto Credential product, “a set of common standards and infrastructure that will help verify...more

Morgan Lewis

Successful Oil Excise Tax Challenge Leads to Opportunities and Uncertainty for Exporters

Morgan Lewis on

A recent challenge to the constitutionality of the federal excise tax on domestic crude oil exported from the United States proved successful in the US Court of Appeals for the Fifth Circuit. While the US Department of...more

Polsinelli

New York Alleges Trump Procured Inflated Appraisals for Conservation Easements

Polsinelli on

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

Freeman Law

Tax Court in Brief | Lamprecht v. Comm’r | Qualified Amended Return and Foreign Banking Reporting

Freeman Law on

Tax Litigation:  The Week of August 29th, 2022, through September 2nd, 2022 Sparta Pink Property, LLC v. Comm’r, T.C. Memo. 2022-88 | August 29, 2022 | Lauber, J. | Dkt. No. 12114-20 Pressman v. Comm’r, T.C. Summ. Op....more

Polsinelli

The DOJ and IRS Focus Enforcement on Syndicated Conservation Easements

Polsinelli on

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

Mitchell, Williams, Selig, Gates & Woodyard,...

Federal Court Authorizes Service of John Doe Summons Seeking Cryptocurrency User Identities

Mitchell, Williams, Selig, Gates & Woodyard,... on

Back in 2005 when I was a trial attorney at the United States Department of Justice, I worked to enforce the John Doe summons on PayPal, Inc. in the federal district court in the Northern District of California, which summons...more

Oberheiden P.C.

What Tax Preparers Need to Know Before Sitting for an IRS CI Interview

Oberheiden P.C. on

The Internal Revenue Service’s Criminal Investigation Division (IRS CI) is targeting tax preparers or the ones who prepare tax returns in 2022. IRS CI is focusing its efforts on tax preparers who underreport their clients’...more

Freeman Law

The IRS, Fraudulent Transfers, and Transferee Liability

Freeman Law on

Can you be held liable for a tax liability owed by another taxpayer?  Yes, under certain circumstances.  The IRS  uses fraudulent transfer law and “transferee” liability tools to collect unpaid taxes where a taxpayer has...more

Bracewell LLP

The IRS Is Mining for Crypto Account Holders

Bracewell LLP on

For years, the cryptocurrency wallets of U.S. taxpayers have existed in a reporting gray zone. However, as it becomes clear that crypto asset transactions are not slowing down, the Internal Revenue Service (IRS) has signaled...more

Freeman Law

Yet Another Streamlined Filing Turns into a Criminal Indictment, Implicating Former CPA and Businessman

Freeman Law on

A recent IRS Criminal Investigation press release announced an indictment against a businessman charged with defrauding the United States by not disclosing offshore assets, failing to report income to the IRS, and submitting...more

Freeman Law

DOJ-Tax Alleges President of We Build the Wall Filed a False Tax Return and Committed Wire Fraud

Freeman Law on

Taxpayers who file false tax returns with the IRS can find themselves in hot water.  Indeed, section 7206(1) of the Internal Revenue Code (“Title 26”) makes it a felony to file a false return when the taxpayer knows that the...more

Freeman Law

[Webinar] Freeman Law International Tax Symposium – General Attendee - November 18th - 19th, 8:00 am - 5:00 pm CST

Freeman Law on

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more

McDermott Will & Emery

Key Takeaways | Cryptocurrency Global Tax Enforcement: What Investors and Companies in the Industry Need to Know NOW

McDermott Will & Emery on

During a recent program discussing the latest government enforcement efforts related to cryptocurrency, we spoke with Gary Alford, one of the leading Internal Revenue Service (IRS) agents in their crypto enforcement efforts,...more

Freeman Law

Reliance on a Third Party as a Defense in Section 7202 Payroll Cases

Freeman Law on

Section 7202 of the Code makes it a felony for any person to willfully fail to collect and pay over payroll taxes to the IRS.  Put simply, a taxpayer may be subject to jail time if the government merely proves that the...more

McDermott Will & Emery

[Webinar] Cryptocurrency Global Tax Enforcement: What Investors and Companies in the Industry Need to Know NOW - June 28th, 12:00...

McDermott Will & Emery on

Following the US Internal Revenue Service’s (IRS) announcement of “Operation Hidden Treasure,” companies and individuals should prepare for increased scrutiny of virtual currency transactions. Unveiled in March, the operation...more

Hogan Lovells

Biden Administration aims to increase IRS enforcement against high earners and corporations

Hogan Lovells on

A significant focus on tax compliance and follow-up enforcement actions may be on the horizon. We previously reported that the Internal Revenue Service (IRS) Cyber Crimes Unit had signaled its determination to increase...more

Jones Day

New Appellate Court Ruling on Priority of Straddle-Year Taxes in Bankruptcy

Jones Day on

A basic tenet of bankruptcy law, premised on the legal separateness of a debtor prior to filing for bankruptcy and the estate created upon a bankruptcy filing, is that prepetition debts are generally treated differently than...more

Burr & Forman

Unpaid Federal Employment Taxes: The Government’s Chief Enforcement Priority

Burr & Forman on

Businesses that have employees must pay wages and salaries to their employees, and the employer must collect federal employee income taxes and the employee’s share of social security (FICA) from these wages and salaries, add...more

Rosenberg Martin Greenberg LLP

What to Do (and Not Do) to Resolve Your Offshore Tax Issues

Rosenberg Martin Greenberg LLP on

In recent months, the Internal Revenue Service (“the Service”) began the process of issuing follow-up letters to taxpayers who either requested preclearance to participate in the Offshore Voluntary Disclosure Program (“OVDP”)...more

36 Results
 / 
View per page
Page: of 2
Next »

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up Log in
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide