News & Analysis as of

John Doe Investigation

IRS Signals Intent to Aggressively Pursue Undisclosed Offshore Accounts

by Varnum LLP on

At the recent National Institute on Criminal Tax Fraud and Tax Controversy, senior IRS and Department of Justice (Tax) officials sounded the proverbial warning alarm to taxpayers with undisclosed or offshore financial...more

Court Enforces — Partially — IRS “John Doe” Summons Served on Virtual Currency Exchanger

by Ballard Spahr LLP on

Last week, a federal magistrate judge in the Northern District of California granted in part and denied in part a motion by the IRS to enforce a “John Doe” summons served on Coinbase, Inc., which operates a virtual currency...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

Coinbase Ordered To Turn Over Bitcoin Trading Records Of Over 14,000 Customers To Internal Revenue Service

by Fox Rothschild LLP on

The Internal Revenue Service has prevailed in its long-running dispute with Coinbase, the largest U.S.-based Bitcoin exchange, with a federal judge ordering Coinbase to comply with a “John Doe” summons seeking customer...more

Red Wings vs Right Wings: Copyright Tarnishment and Other Lessons

by Revision Legal on

We wrote recently about our outrage at white nationalists modifying and using the Detroit Red Wing’s famous “winged wheel” logo. Our outrage continues and we take a closer look at the potential lawsuit that might be in order....more

Cryptocurrency Traders Beware – The Taxman Cometh!

As the collective market cap of the cryptocurrencies has jump above $150 billion, traders and investors have accumulated significant gains. That’s the good news. The bad news is that the Internal Revenue Service is stepping...more

California Employers May Sue For Online Defamation

by Fisher Phillips on

The situation is a familiar one. Disgruntled current or former employees leave negative and harmful comments about their employer on online workplace review websites such as glassdoor.com or vault.com, or on customer review...more

Blockchain Week in Review – May 2017 #4

by Perkins Coie on

Below is a summary of some of the significant legal and regulatory actions that occurred over the past week. This alert is not intended to be a comprehensive list of all such developments, but rather a selection of...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

The Summons

by Moskowitz LLP on

Coinbase is a San Francisco-based cryptocurrency exchange company that operates bitcoin and other digital asset transactions and storage for over one million users in 190 countries....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

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

Canadian IP law and practice in 2016: reviewing the highlights

by Smart & Biggar on

As the calendar turns the page from 2016 to 2017, we take the opportunity to review Canadian IP law and practice highlights from the past year....more

U.S. Department of Justice Obtains Court Order Authorizing IRS to Investigate Bitcoin Users

by Ropes & Gray LLP on

Using the same procedure it used to crack the secrecy of Swiss Banks, on November 30, 2016, the U.S. Department of Justice obtained a court order allowing the IRS to issue a “John Doe” summons to Coinbase Inc., the largest...more

Global Tax Enforcement in 2016: What You Need to Know

by BakerHostetler on

The investigation and prosecution of tax evasion has, in the past decade, grown from a specialized subcategory of law enforcement into a first-tier policy concern for the international community. Financial institutions,...more

Focus on Tax Controversy and Litigation - Second Circuit Determines that Tax Memo Shared Between Taxpayers and Banks Is Protected...

by Shearman & Sterling LLP on

In addition to the discussion of the Second Circuit’s decision in Schaeffler, this month’s issue features articles regarding the “new” IRS Notices covering “Basket Options” and “Basket Contracts”, the Tax Court’s recent...more

IRS Seeks Identities of Americans with Undisclosed Belize Bank Accounts

by Foley & Lardner LLP on

Americans with secret accounts in Belize should take notice: the government is looking for you. The U.S. Department of Justice on September 15 filed a petition in federal court in Miami seeking permission to issue summonses...more

IRS Targets a Belize Bank with a “John Doe” Summons

by Blank Rome LLP on

The Internal Revenue Service will now obtain information on U.S. accountholders at a Belize bank – Belize Bank International Limited (“BBIL”) or Belize Bank Limited (“BBL”). Yesterday, the Justice Department announced that a...more

Who is John Doe? Actor James Woods Brings “Twibel” Case Against Anonymous User “Abe List” for Calling Him A “Cocaine Addict”

by Kelley Drye & Warren LLP on

Last week, renowned film and television actor James Woods brought a defamation claim against an anonymous Twitter user who tweets from the handle “Abe List,” alleging that Abe List falsely accused Woods of being a cocaine...more

BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement

by BakerHostetler on

Global tax enforcement is the number one priority of the U.S. authorities, and they are using their resources and tools in unprecedented ways to ensure that those who intentionally evade taxes are identified and brought to...more

Don’t Shoot the Messenger: The Expanding Scope of the John Doe Summons

The John Doe summons is an information-gathering tool that has been available to the IRS for many years, traditionally used to seek information about unknown persons suspected of tax evasion from banks, investment advisors or...more

Voluntary Disclosures Lead to John Doe Summonses for Information about U.S. Accounts at Zurcher Kantonalbank and Bank of...

by BakerHostetler on

In a sign that the U.S. government continues to aggressively seek information on U.S. taxpayers with non-U.S. bank accounts, the government announced on November 12, 2013, that it had obtained a court order authorizing the...more

U.S. Seeks John Doe Summonses for Two More U.S. Banks

by BakerHostetler on

The Chicago Tribune reports that U.S. authorities are seeking information from Citigroup Inc.’s Citibank NA and Bank of New York Mellon Corp to uncover the identities of U.S. citizens who may have been hiding money in Swiss...more

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Cybersecurity

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