News & Analysis as of

Criminal Investigations Internal Revenue Service Voluntary Disclosure

Foodman CPAs & Advisors

ERC Voluntary Disclosure Program Re-Opens

On 7/15/24, the IRS announced via Notice IR-2024-212 the re-opening of the ERC (Employee Retention Credit) Voluntary Disclosure Program which will end on 11/22/24. The first ERC Voluntary Disclosure Program ended in March...more

Husch Blackwell LLP

IRS Introduces Second Opportunity for ERC Claimants to Correct Errors

Husch Blackwell LLP on

On August 15, 2024, the Internal Revenue Service (IRS) launched a second Employee Retention Credit (ERC) Voluntary Disclosure Program for employers to correct any mistakes related to their ERC claims. The ERC, introduced by...more

Fox Rothschild LLP

IRS Reopens Employee Retention Tax Credit Voluntary Disclosure Program

Fox Rothschild LLP on

The ERC is a legitimate, refundable tax credit designed to help businesses that continued to pay employees while they were shut down because of the COVID-19 pandemic or that experienced a significant decline in gross receipts...more

Fox Rothschild LLP

IRS Begins Processing Some Employee Retention Tax Credit Claims Filed During the Moratorium

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The Internal Revenue Service has adjusted its moratorium on processing Employee Retention Tax Credit (ERC) claims, announcing last week it will begin processing claims filed between September 14, 2023 and January 31, 2024. In...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

Womble Bond Dickinson

IRS Continues Aggressive Oversight and Enforcement of Employee Retention Credits

Womble Bond Dickinson on

The Employee Retention Credit (ERC) is a refundable tax credit for businesses whose employees were impacted by the COVID-19 Pandemic. The provisions are set out in § 2301 of the CARES Act and § 3111 of the Internal Revenue...more

Kramer Levin Naftalis & Frankel LLP

Voluntary Disclosure Program Announced for Pandemic-Related Employee Retention Credits

On Dec. 21, 2023, the IRS announced the Employee Retention Credit Voluntary Disclosure Program (ERC-VDP), which helps eligible taxpayers pay back the money they had received for erroneously filed Employee Retention Credit...more

Jackson Walker

IRS Announces Voluntary Disclosure Program for Employee Retention Tax Credits

Jackson Walker on

On December 21, 2023, the Internal Revenue Service (IRS) issued Announcement 2024-3, setting forth the parameters of a voluntary disclosure program (the “Program”) for taxpayers to resolve Employee Retention Tax Credit (ERTC)...more

Fox Rothschild LLP

New IRS Program Lets Businesses Repay Questionable Employee Retention Credits at a Discount

Fox Rothschild LLP on

The Internal Revenue Service has announced a new Voluntary Disclosure Program (VDP) that offers businesses a limited-time opportunity to repay improperly claimed Employee Retention Credits (ERC) at a discount while avoiding...more

Baker Donelson

IRS Increases ERC Enforcement and Prepares to Launch New Voluntary Disclosure Program

Baker Donelson on

In an ongoing effort to combat suspect Employee Retention Credit (ERC) claims, on December 6 the IRS announced that it will issue an initial round of more than 20,000 letters disallowing some ERC claims, filed by "fictitious"...more

BakerHostetler

IRS Enforcement Efforts in Puerto Rico Gaining Steam - Wave of Cases Expected

BakerHostetler on

Long-awaited enforcement actions may be coming soon for those who took advantage of the lucrative tax breaks offered by the Commonwealth of Puerto Rico without meeting the requirements. Prosecutions may also follow for...more

McDermott Will & Emery

Key Takeaways | Cryptocurrency Global Tax Enforcement: What Investors and Companies in the Industry Need to Know NOW

McDermott Will & Emery on

During a recent program discussing the latest government enforcement efforts related to cryptocurrency, we spoke with Gary Alford, one of the leading Internal Revenue Service (IRS) agents in their crypto enforcement efforts,...more

McDermott Will & Emery

[Webinar] Cryptocurrency Global Tax Enforcement: What Investors and Companies in the Industry Need to Know NOW - June 28th, 12:00...

McDermott Will & Emery on

Following the US Internal Revenue Service’s (IRS) announcement of “Operation Hidden Treasure,” companies and individuals should prepare for increased scrutiny of virtual currency transactions. Unveiled in March, the operation...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

Holland & Knight LLP

Virtual Currency: The Taxman is Coming

Holland & Knight LLP on

Virtual currency transactions are now a prime focus of Internal Revenue Service (IRS) scrutiny. The IRS has numerous information-gathering tools to enforce its taxing power, including summons, artificial intelligence, data...more

Dickinson Wright

Updated Voluntary Disclosure Practice Rules

Dickinson Wright on

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

White and Williams LLP on

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

Perkins Coie on

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

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