News & Analysis as of

Tax Evasion

Supreme Court Holds DOJ’s Feet to the Fire in Tax Crime Case

by McGuireWoods LLP on

In Marinello v. United States, an opinion released yesterday, the Supreme Court adopted a narrowing interpretation of the tax code’s broadest criminal provision, the “tax obstruction” statute 26 U.S.C. § 7212(a). The Court’s...more

IRS Is Closing Offshore Voluntary Disclosure Program; Deadline of September 28, 2018

The IRS announced it will be closing its Offshore Voluntary Disclosure Program (OVDP) as of September 28, 2018. The news follows a significant decrease in taxpayer participation in the program, coupled with advances in...more

IRS Announces End of FBAR Voluntary Disclosure Program

As I discussed in a prior blog post, if you have more than $10,000 in a foreign bank account, you are obligated to file Form 114 (commonly known as an FBAR). Failure to make this filing can result in significant civil...more

Criminal Tax Obstruction Case Argued Before the Supreme Court

by Moskowitz LLP on

This past December, the Supreme Court heard the first criminal tax case to be argued before it in a decade. The Court agreed to hear the case following a petition by Carlo J. Marinello, II, a freight service businesses owner...more

U.S. Internal Revenue Service Cancels Offshore Amnesty Program

by Butler Snow LLP on

The U.S. Internal Revenue Service has just announced that it will end the Offshore Voluntary Disclosure Program (“OVDP”) on 28 September 2018. ...more

State Crackdown On “Zappers” Continues: Washington State AG Files $5.6 Million Criminal Tax Case Against Restauranteur

by Fox Rothschild LLP on

Calling it the largest sales suppression software case in state history, Washington State Attorney General Bob Ferguson announced the filing of criminal charges last week against the owner of six restaurants for allegedly...more

FINCEN Advises That Participation in a Foreign Tax Regularization Program By Itself Does Not Trigger SAR Filing Obligation

by Ballard Spahr LLP on

The Financial Crimes Enforcement Network (“FinCEN”) recently advised that a financial institution is not required to file a Suspicious Activity Report (“SAR”) based solely upon a customer’s inquiry into or participation in a...more

IRS Increases Focus on Criminal Prosecution of Cryptocurrency Tax Evasion: What You Need to Know before Tax Day

by Blank Rome LLP on

Blockchain Technology & Digital Currencies March 2018 (No. 1) In 2017, the world witnessed virtual currency investors become millionaires seemingly overnight with cryptocurrencies, such as Bitcoin, climbing from $830 to...more

Foreign Account Reporting: Time Limit for IRS Action

by Moskowitz LLP on

To conduct an audit or otherwise take action on a tax return, the IRS must generally act within three years from the later of either the return’s due date or the date it was filed. That time limit may be extended to six years...more

Brussels Regulatory Brief: March 2018

by K&L Gates LLP on

Antitrust and Competition - Another transaction in the technology sector referred to the European Commission for its review - The European Commission (“Commission”) is yet again set to review a transaction in the technology...more

Tax Evasion Contributes To Loss Of Professional License

by Moskowitz LLP on

If you are avoiding your tax obligations, you risk even more than civil and criminal prosecution. A collateral consequence of a tax delinquency may be loss of your driver’s and/or professional license....more

Los Angeles Business Owner Charged With Income and Payroll Tax Fraud

by Moskowitz LLP on

A successful Los Angeles businessman seems to have missed the part about paying his taxes. Following a cooperative investigation by the U.S. Department of Justice, California Franchise Tax Board (FTB), and California...more

The IRS is on to Crypto

by Foodman CPAs & Advisors on

The IRS Chief of Criminal Investigation, Don Fort, recently stated: “It’s possible to use Bitcoin and other cryptocurrencies in the same fashion as foreign bank accounts to facilitate tax evasion.” ...more

Circuit Resolves Jurisdictional Questions In Context Of Section 853(n) Asset Forfeiture Proceeding

In a short opinion in United States v. Ohle, 16-601-cr, the Second Circuit (Leval, Calabresi, Cabranes) resolved two open questions about the application of Federal Rule of Appellate Procedure 4, both in the context of a...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

Walmart’s shares took a hit yesterday on Q4 results that showed slowing online sales and below-expected earnings despite a rise in revenue....more

Court Orders Jacobson Remand to Determine Reasonableness of $10 Million Fine

In United States v. Zukerman, No. 17-948 (2d Cir. Feb. 6, 2018) (ALK, RAK, RSP) (summary order), the appellant, Morris Zukerman, challenged the substantive and procedural reasonableness of his sentence, which was imposed...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

Court Orders Jacobson Remand to Determine Reasonableness of $10 Million Fine

In United States v. Zukerman, No. 17-948 (2d Cir. Feb. 6, 2018) (ALK, RAK, RSP) (summary order), the appellant, Morris Zuckerman, challenged the substantive and procedural reasonableness of his sentence, which was imposed...more

Pension Alert - February 2018

by Hogan Lovells on

Featured is a reminder regading action needed on legacy protected rights rules and new briefings on New offences under the Criminal Finances Act 2017; Reducing your PPF levy; VAT and pension schemes; and an updated briefing...more

U.S. Court Favors Aircraft Financier in Non-Citizen Trust Case

District court case shines a light on the extent and limits of a lender’s duties in both structuring loan transactions and exercising remedies. Borrowers need to be mindful in structuring the tax and cross-border aspects...more

News Now: Your One Minute Legal Insight (Embryos, Marijuana, TABOR, and More)

by Sherman & Howard L.L.C. on

As always, there are a lot of topics to cover in this edition of News Now. Here are your highlights...more

New offences under the Criminal Finances Act 2017: are corporate pension trustees at risk?

by Hogan Lovells on

The Criminal Finances Act 2017 creates two new offences concerning tax evasion, potentially relevant to pension scheme corporate trustees (but not individual trustees). Corporate pension trustees should consider whether they...more

Mississippi Is Latest State To Consider Outlawing Tax “Zapper” Software

by Fox Rothschild LLP on

Lawmakers in Mississippi are tackling the pervasive use of automated sales suppression devices, commonly known as “zappers,” by businesses to hide a portion of their sales and thereby avoid paying sales tax. Zapper programs...more

A Day Of Reckoning For Recalcitrant Taxpayers?

by Carlton Fields on

Following disclosures by UBS whistleblower Bradley Birkenfeld, the IRS launched an aggressive enforcement campaign against undeclared offshore income and financial accounts in 2009. Over time, it has offered a series of...more

10 EU Competition & Regulatory Trends to Watch for in 2018

Introduction - Our “trends for 2018” are only a selection of interesting developments to watch for in 2018. Within the political and legislative cycle of the European Union, 2018 promises to be an eventful year, given...more

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