News & Analysis as of

Tax Evasion Internal Revenue Service

Update on IRS Offshore Initiatives: Investigations and agreements with financial institutions worldwide

by Moskowitz LLP on

In our last post, we noted that the U.S. government goes to great lengths to identify and prosecute noncompliant taxpayers, as well as promoters and financial institutions who assist U.S. taxpayers avoid their tax obligations...more

Update on IRS Offshore Initiatives

by Moskowitz LLP on

Global tax issues are a top priority for the Internal Revenue Service Criminal Investigation Division (IRS-CI), which focuses its work on investigating taxpayers who willfully engage in tax evasion. Significant efforts are...more

More Data Added To Paradise Papers Offshore Leaks Database

by Fox Rothschild LLP on

Yesterday the International Consortium of Investigative Journalists released information from the corporate registries of four more tax havens that were included in the Paradise Papers investigation: Barbados, the Bahamas,...more

News Round Up - December 2017

by Morrison & Foerster LLP on

The Short Field Guide to IPOs - For many years, most successful companies followed a relatively predictable capital-raising path. A lot has changed. The companies that tend to pursue IPOs in recent years are more mature,...more

Cryptocurrency Exchanges - the New Front of the IRS War on Tax Evasion?

by Morrison & Foerster LLP on

On November 29, 2017, the U.S. District Court for the Northern District of California dealt a partial blow to the U.S. Department of Justice and the IRS in connection with their collective efforts to enforce an expansive and...more

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

U.S. v. Coinbase: Virtual Currency Holders Not Outside the IRS’s Reach

by Dechert LLP on

The U.S. District Court for the Northern District of California, on November 28, 2017, ordered the international digital currency broker, Coinbase, Inc., to produce to the Internal Revenue Service (IRS) the records of...more

Senator Rand Paul Once Again Takes Aim At FATCA

by Fox Rothschild LLP on

In the midst of the tax reform debate currently embroiling Congress, Senator Rand Paul (R-Kentucky) has introduced an amendment seeking to repeal the Foreign Account Tax Compliance Act (FATCA), an anti-tax evasion law enacted...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

Offshore Assets May Be Subject to Enforced Collection by the IRS

by Sanford Millar on

The fact that you may have assets offshore does not mean that they are immune from seizure by the IRS. A recent case illustrates how the IRS can enforce collection outside the United States....more

The Manafort Indictment and what it means to you.

by Sanford Millar on

On October 30, 2017 Paul Manafort, the former campaign chair for president Donald Trump was indicted by a Federal Grand Jury in the District of Columbia. The charges arise from Manafort's unregistered consulting and...more

Manafort Indictment Alleges High-End International Money Laundering and Tax Fraud Involving Offshore Accounts

by Ballard Spahr LLP on

As the world now knows, an indictment against Paul Manafort, Jr., a former campaign chairperson for now-President Donald Trump, and Manafort’s associate, Richard Gates III, was unsealed yesterday. ...more

You are Contacted by an IRS Criminal Investigator: What Do You Do? Defending an IRS Criminal Investigation (Part 11)

by McNair Law Firm, P.A. on

The IRS investigates criminal violations of federal tax laws, including tax evasion, tax fraud, and not filing tax returns. Many people do not realize that simply not filing a tax return when it is due is a crime under...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

"Money" Mayweather’s $22 Million Tax Problem

by Moskowitz LLP on

Floyd "Money" Mayweather certainly lives up to his nickname – the undefeated boxer is expected to cash in as much as $350 million for his recent win against Irish UFC fighter Conor McGregor....more

Tax Return Preparer Sentenced to 27 Months for Tax Evasion

by Moskowitz LLP on

Tax evasion carries severe penalties, even in cases in which no one else has been defrauded. The facts - From 2005 through 2011, Semere Tsehaye owned more than 20 Instant Tax Service (ITS) franchises in Illinois, Kansas...more

San Antonio Businessman Sentenced To Four Years in Prison for Defrauding Personal Injury Clients, the Bankruptcy court, and the...

by Moskowitz LLP on

From 2009 through 2014, Elpidio Gongora (aka “Pete Gongora”), operated a number of personal injury law offices in Texas, Arkansas and New Mexico. The lawyers in these firms apparently obtained settlements on behalf of their...more

18 Months in Prison for Cashing Client Checks and Not Reporting the Income to the IRS

by Moskowitz LLP on

A man who provided landscaping and snowplowing services to residential and commercial customers in Hartford, Connecticut is serving 18 months in jail for underreporting his income....more

U.S. Withholding on Synthetic Trades over U.S. Equities—Further Delay of Full Implementation Until 2019 (Notice 2017-42)

In response to perceived abuses in taxpayers’ use of swaps and other derivative transactions (e.g., options, futures or forwards) to avoid withholding tax on U.S. source dividends, Congress added Section 871(m) to the...more

IRS and States Crack Down on POS Systems: Zapper Software

by Bowditch & Dewey on

A good point of sale (“POS”) system is critical for any business engaged in sales to the public and having one in place goes a long way to ensuring that revenue and profits are being reported properly to federal, state and...more

Cumplimiento Fiscal Internacional

by Foodman CPAs & Advisors on

Detectar, disuadir y responder al incumplimiento internacional son desafíos clave que enfrentan las autoridades tributarias de todo el mundo. El incumplimiento fiscal internacional es un problema significativo reconocido por...more

Unfiled Tax Returns: What Do You Do? (Part 2)

by McNair Law Firm, P.A. on

The United States has a voluntary income tax reporting system. U.S. citizens, permanent residents, and businesses here must annually file income tax returns with the IRS, reporting their “worldwide income”, deductions, and...more

No Rest For The Weary: Offshore Tax Evasion Crackdown Continues With Flurry Of Mid-Summer Activity

by Fox Rothschild LLP on

Dashing any thought that they were taking a hiatus from investigating and prosecuting taxpayers with secret offshore bank accounts and the bankers that helped them, the Justice Department and Internal Revenue Service have...more

The Complete Saga of Former U.S. Tax Court Judge Diane L. Kroupa is Now Finally Concluded

by Garvey Schubert Barer on

As reported in my April 7, 2016, October 3, 2016 and October 27, 2016 blog posts, former U.S. Tax Court Judge Diane L. Kroupa and her then husband, Robert E. Fackler, were indicted on charges of tax fraud. Specifically, they...more

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