News & Analysis as of

Criminal Investigations Internal Revenue Service Offshore Funds

McGlinchey Stafford

TIGTA Reports: Virtual Currency Tax Compliance Enforcement Can Be Improved

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The number of virtual currency types has added to this problem. According to TIGTA, the number of virtual currencies has grown significantly since April 2020, from 5,000 to over 26,000 (420 percent) as of July 2023. The two...more

Foodman CPAs & Advisors

Práctica IRS Divulgación Voluntaria

Los contribuyentes que intencionalmente han no han cumplido con obligaciones tributarias o relacionadas con impuestos pueden resolver su incumplimiento y limitar su exposición a un proceso penal presentando una solicitud a la...more

Foodman CPAs & Advisors

IRS Voluntary Disclosure Practice

Taxpayers that have willfully failed to comply with tax or tax-related obligations may be able to resolve their non-compliance and limit their exposure to criminal prosecution by filing an application to the IRS Voluntary...more

Freeman Law

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

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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

IRS Gets Green Light to Seek Information from Third Parties Regarding Panama Offshore Legal Services

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On July 29, 2021, the United States Attorney for the Southern District of New York, the Assistant Attorney General for the Department of Justice Tax Division, and the IRS Commissioner all announced that a federal court in New...more

Oberheiden P.C.

Eleven of the IRS's Enforcement Priorities During the 2021 Tax Season

Oberheiden P.C. on

It is tax season once again. While the Internal Revenue Service (IRS) has extended this year’s filing deadline to May 17, 2021 for individuals, businesses must still file by April 15, and all U.S. taxpayers must ensure that...more

Foodman CPAs & Advisors

“Complexity will not hide crime from law enforcement,” California U.S. Attorney on Brockman Indictment

The U.S. Department of Justice (DOJ) 39 count indictment charging Robert T. Brockman, with tax evasion, wire fraud, money laundering, and other offenses, demonstrates that the DOJ is committed to the investigation and...more

Dickinson Wright

Updated Voluntary Disclosure Practice Rules

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On September 28, the IRS ended its 2014 Offshore Voluntary Disclosure Program (“OVDP”). The IRS issued a memorandum—dated November 20, 2018—to announce its new Updated Voluntary Disclosure Practice rules. The IRS memorandum...more

Rosenberg Martin Greenberg LLP

Offshore Update: IRS Releases Memorandum Addressing Updates to Voluntary Disclosure Practice After Closing Offshore Voluntary...

Now, More than Ever, Taxpayers with Lingering Offshore Tax Non-Compliance Must Seek Professional Assistance - On November 20, 2018, the Internal Revenue Service (“the Service”) released a memorandum containing important...more

Foodman CPAs & Advisors

IRS gives Internal Revenue Manual Voluntary Disclosure Consideration if…….

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When IRS reviews a criminal tax case, consideration is given to various factors such as whether a voluntary disclosure was made, whether prosecution exists, the health, age and mental condition of the Taxpayer and whether a...more

Butler Snow LLP

Submit OVDP Preclearance Letter by the End of this Week

Butler Snow LLP on

The IRS requires that Offshore Voluntary Disclosure Program (“OVDP”) preclearance letters be submitted to IRS Criminal Investigations by August 24, 2018. Taxpayers only have five more days to submit the OVDP preclearance...more

White and Williams LLP

IRS Announces Significant Changes to Offshore Account Disclosure Programs

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The Internal Revenue Service (IRS) recently announced significant changes to its Offshore Voluntary Disclosure Program (OVDP), which it first offered in 2009. The IRS revised OVDP over the years, including introducing the...more

Perkins Coie

IRS Announces End to Offshore Amnesty Program

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The IRS recently announced that it would end the Offshore Voluntary Disclosure Program (OVDP). The OVDP is an amnesty program that tens of thousands of taxpayers have used since 2009 to report previously undisclosed foreign...more

Ballard Spahr LLP

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

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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

Holland & Knight LLP

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

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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

Blank Rome LLP

Justice Department Announces That Three More Swiss Banks Reach Agreements Over Tax Evasion Claims

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On July 30, 2015, the Justice Department’s Tax Division announced that three more Swiss banks — PKB Privatbank AG, Falcon Private Bank AG and Credito Privato Commerciale in liquidazione SA (CPC) – have cut deals with the U.S....more

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