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Department of Justice (DOJ) Tax Liability Internal Revenue Service

Cadwalader, Wickersham & Taft LLP

Crypto: Give Unto Caesar What Is Caesar’s

Earlier this year the U.S. Department of Justice (“DOJ”) brought USA v. Ahlgren, its first crypto case with tax evasion allegations unrelated to another crime, demonstrating the DOJ’s willingness to pursue stand-alone crypto...more

Polsinelli

CPA gets 25 years for Promoting Conservation Easement Deductions

Polsinelli on

Judge Batten, Chief United States District Judge for the Northern District of Georgia, handed down lengthy sentences in the first-of-its-kind criminal trial related to syndicated conservation easements (“SCEs”). On January...more

Gray Reed

The IRS is Attacking Abusive Trust Arrangements

Gray Reed on

Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more

Polsinelli

Conservation Easements: Palpable Fraud or Honest Mistakes? A Federal Jury Returns a Split Verdict

Polsinelli on

On September 22, 2023 a federal jury convicted two promoters, CPA Jack Fisher and attorney James Sinnott, in the Department of Justice’s (“DOJ”) first criminal trial over allegedly abusive syndicated conservation easements...more

Rivkin Radler LLP

Tax Compliance: Self-Assessment, Transparency, and Enforcement

Rivkin Radler LLP on

NY’s Almost There- Back in June of this year, New York’s legislature passed a bill that, if enacted, would create the first state-level public database with information regarding the ownership of limited liability...more

McDermott Will & Emery

Can the Government Sue for Tax Debts Outside IRC Procedures?

McDermott Will & Emery on

On June 1, 2023, in United States v. Liberty Global, Inc.[1], the US District Court for the District of Colorado held that the US Department of Justice (DOJ) can assert and seek judgment for federal income tax deficiencies...more

Miller Canfield

High-Profile Case Highlights Government's Common Law Right to Pursue Tax Deficiencies in Court

Miller Canfield on

A federal district court ruled in a high-profile case that the Justice Department may rely on common law rather than the statutory notice of tax deficiency procedure in the Internal Revenue Code to assert a federal income tax...more

BakerHostetler

IRS Warns: Hundreds of Crypto Criminal Tax Cases Coming Soon; Hiring of 300 Special Agents Means More to Follow

BakerHostetler on

Takeaways: ..2022 IRS Criminal Investigation Annual Report highlights significant prosecutions and identifies cryptocurrency as an area of top priority heading into 2023. ..Criminal Investigation Chief Jim Lee...more

Freeman Law

Tax Court in Brief | Lamprecht v. Comm’r | Qualified Amended Return and Foreign Banking Reporting

Freeman Law on

Tax Litigation:  The Week of August 29th, 2022, through September 2nd, 2022 Sparta Pink Property, LLC v. Comm’r, T.C. Memo. 2022-88 | August 29, 2022 | Lauber, J. | Dkt. No. 12114-20 Pressman v. Comm’r, T.C. Summ. Op....more

Polsinelli

The DOJ and IRS Focus Enforcement on Syndicated Conservation Easements

Polsinelli on

Earlier this year, the Department of Justice filed the first criminal indictment of promoters, appraisers and accountants connected to an alleged scheme to create syndicated conservation easements. The move followed increased...more

BakerHostetler

The Tax Man Is Back: IRS Issues First John Doe Summons in 2022 to Major Crypto Platform, Seeking Treasure Trove of Information on...

BakerHostetler on

Key Takeaways: ..The IRS issued its fourth John Doe summons against digital asset platform sFOX, seeking information regarding user identity and transaction activity over $20,000. ..The use of John Doe summonses...more

Oberheiden P.C.

What Tax Preparers Need to Know Before Sitting for an IRS CI Interview

Oberheiden P.C. on

The Internal Revenue Service’s Criminal Investigation Division (IRS CI) is targeting tax preparers or the ones who prepare tax returns in 2022. IRS CI is focusing its efforts on tax preparers who underreport their clients’...more

Freeman Law

IRS Voluntary Disclosures and Criminal Employment Tax Violations

Freeman Law on

Taxpayers who employ workers have obligations under federal law to withhold and remit federal employment taxes to the IRS. In addition to this withholding and payment requirement, federal law also imposes certain reporting...more

Freeman Law

The IRS, Fraudulent Transfers, and Transferee Liability

Freeman Law on

Can you be held liable for a tax liability owed by another taxpayer?  Yes, under certain circumstances.  The IRS  uses fraudulent transfer law and “transferee” liability tools to collect unpaid taxes where a taxpayer has...more

Freeman Law

DOJ-Tax Alleges President of We Build the Wall Filed a False Tax Return and Committed Wire Fraud

Freeman Law on

Taxpayers who file false tax returns with the IRS can find themselves in hot water.  Indeed, section 7206(1) of the Internal Revenue Code (“Title 26”) makes it a felony to file a false return when the taxpayer knows that the...more

Freeman Law

[Webinar] Freeman Law International Tax Symposium – General Attendee - November 18th - 19th, 8:00 am - 5:00 pm CST

Freeman Law on

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...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

Gray Reed

Guidelines for Protecting Privilege in Tax Cases

Gray Reed on

Lawyers, tax or otherwise, understand that privileged information must be protected to encourage a full and frank dialogue that might not occur without confidentiality.1 Tax information, in particular, contains some of the...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

Jones Day

New Appellate Court Ruling on Priority of Straddle-Year Taxes in Bankruptcy

Jones Day on

A basic tenet of bankruptcy law, premised on the legal separateness of a debtor prior to filing for bankruptcy and the estate created upon a bankruptcy filing, is that prepetition debts are generally treated differently than...more

Burr & Forman

Criminal Tax Restitution: Who Can Tell Me What I Owe the IRS?

Burr & Forman on

Individuals who are the unfortunate subjects of federal criminal tax prosecution face prison terms, probation, fines, restrictions on travel and other punishment. Conviction of felony tax offenses results in certain...more

Burr & Forman

Unpaid Federal Employment Taxes: The Government’s Chief Enforcement Priority

Burr & Forman on

Businesses that have employees must pay wages and salaries to their employees, and the employer must collect federal employee income taxes and the employee’s share of social security (FICA) from these wages and salaries, add...more

BakerHostetler

Former Head of DOJ Tax Division Warns Taxpayers to Think Twice Before Choosing New Streamlined Procedures

BakerHostetler on

Former DOJ Tax Division AAG Kathy Keneally warned on June 24, 2014, that taxpayers should think carefully before signing a certification of non-willfulness and entering the IRS’s new Streamlined Filing Compliance Procedures....more

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