News & Analysis as of

Tax Evasion Dept. of Justice

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

Paradise Papers, Panama Papers…. The Message is Clear: Report Offshore Accounts!

by Foodman CPAs & Advisors on

First, the Panama Papers, and now… the Paradise Papers. The Paradise Papers contain the names of approximately 31,000 US citizens, including entities, or persons with US addresses....more

Government Enforcement Investigations – What You Need to Know in 2018

On October 4, 2017, Skadden presented the seminar “Government Enforcement Investigations – What You Need to Know in 2018.” Skadden partners Ryan Junck and Elizabeth Robertson, both based in London, moderated the panel...more

Anti-Money Laundering and Bank Secrecy Act Update

by Moore & Van Allen PLLC on

After the Panama Papers exposed efforts by wealthy individuals and government officials to hide funds offshore, government authorities around the world have responded with new legislation, regulations and enforcement actions...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

Will Supreme Court Narrow The Broadest Tax Crime?

by McGuireWoods LLP on

In the October 2017 term, the Supreme Court will take up its first criminal tax case in almost a decade, Marinello v. United States. At issue is a longstanding circuit split about a mainstay of the federal government’s...more

Justice Department’s Latest Offshore Bank Resolution Confirms Value Of Self-Disclosure And Voluntary Remediation By At-Risk...

by Fox Rothschild LLP on

The Justice Department revealed its latest offshore bank resolution by announcing that it had entered into a non-prosecution agreement with a Swiss asset management firm called Prime Partners. This means that Prime Partners...more

Anti-Corruption Digest - July 2017

by Dorsey & Whitney LLP on

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. The Digest puts material regarding anti-corruption enforcement from around the world at your fingertips, keeping you ahead of critical events that impact global...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

On the Eve of Tax Day, Justice Department Warns That Tax Evaders Will Face Prison Time

by Fox Rothschild LLP on

With only four days remaining until “Tax Day,” the Justice Department’s well-publicized campaign to deter potential tax evaders continues with more stern warnings to taxpayers. In a bleak press release entitled “With the...more

As Tax Day Approaches, Justice Department and IRS Turn Up Heat on Potential Tax Cheats

by Fox Rothschild LLP on

With less than two weeks until the April 18 deadline for filing individual federal income tax returns, the Justice Department and Internal Revenue Service are issuing stern warnings to potential tax cheats. Today the U.S....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

Owner of Professional Employer Organization Pleads Guilty to Employment Tax Charge

by BakerHostetler on

On Jan. 6, 2017, Janis Edwards, the owner of a professional employer organization, pleaded guilty to tax evasion arising from failing to pay over to the IRS between $3.5 million and $25 million in withholdings that her...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

The IRS isn’t waiting around for virtual currency to gain wider acceptance. No, it’s more than happy to go after Bitcoin users who have sought to use the virtual currency as a means of evading taxes....more

Tax Evasion - Nowhere Left to Hide

by K&L Gates LLP on

Global tax evasion remains a major problem for governments around the world. At a time when virtually all of the governments from the world’s major economies seek additional revenue, the attractiveness to taxpayers of...more

Corporate Investigations and White Collar Defense - July 2016

“Official Acts”—What They Are… and Are Not - Why it matters: On June 27, 2016, the Supreme Court decided McDonnell v. U.S., holding that, for purposes of the federal public corruption statutes, an “official act”...more

¡Primera Convicción de FATCA!

by Foodman CPAs & Advisors on

El 9 de Mayo del 2016, el Departamento de Justicia (DOJ) anunció su primera convicción usando FATCA. Parece ser el principio de procesos penales por el DOJ contra violaciones aparentes o presuntas de los requisitos de...more

Singapore’s Banking Secrets - Not So Secret Anymore

by K&L Gates LLP on

Since 2008, the U.S. Government has largely focused its enforcement actions against Swiss banks that may have assisted U.S. taxpayers in evading federal taxes. In August 2013, the Department of Justice (“DOJ”) introduced the...more

Hong Kong & Singapore: Awaiting a New DOJ Tax Program for Asian Banks?

As the Department of Justice is wrapping up its prosecution of over a dozen Swiss banks, federal prosecutors and IRS special agents are analyzing a treasure trove of previously undeclared taxpayer account information that...more

Government Investigations: Use of the Financial Crimes Enforcement Network and Virtual Currency

by Moskowitz LLP on

Since 2009, the US Department of Justice has implemented an aggressive anti-tax evasion strategy that has changed by targeting tax havens that host financial intermediaries (i.e., banks) to the financial intermediaries...more

What Attorneys Can Learn from History’s Largest Data Breach

by Wilson Elser on

On April 3, 2016, the public learned that millions of client documents from the Panamanian law firm and corporate services provider Mossack Fonseca & Co. (MF) had made their way to an international organization, the...more

Panama Papers Fallout: A Push for Transparency and Regulatory Reform - Sanctions Also Levied Against Several Panama-Based...

by Holland & Knight LLP on

In the wake of the "Panama Papers" – the unprecedented leak of 11.5 million files from a Panamanian law firm that revealed thousands of names and addresses linked to offshore companies – the White House has announced several...more

What Can You Learn in the First Inning?

by Thomas Fox on

You might figure that the year I decide to jump back on the Houston Astros bandwagon, they go back in the tank. Last year they were one game away from the American League (AL) Championship. This year they have the third worst...more

Tax Day Brings Barrage of Criminal Tax Charges and Warnings

by Blank Rome LLP on

With “Tax Day” upon us, the Justice Department’s Tax Division and U.S. Attorney’s Offices around the country have unleashed an avalanche of press releases warning would-be tax cheats of the severe criminal and civil...more

The Global Spotlight on Transparency: Renewed Focus on Tax and Financial Regulatory Enforcement in Singapore

by K&L Gates LLP on

The global spotlight on transparency in tax and financial reporting has come to Singapore, signalling cause for renewed focus on compliance for investors and global business operators. On 6 April, the Singaporean Ministry of...more

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