News & Analysis as of November 15, 2024

Tax Fraud

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XIII – What...

Foster Garvey PC on 11/14/2024

Basic Rules - IRC § 6501(a) generally requires the IRS to assess tax within three (3) years after a tax return is filed by the taxpayer. There are two (2) notable exceptions to this rule under IRC § 6501(c) and (e),...more

First Stand-Alone Crypto Tax Fraud Case Leads to Guilty Plea

Cadwalader, Wickersham & Taft LLP on 10/24/2024

On September 12, 2024, the U.S. Department of Justice (“DOJ”) announced that Frank Richard Ahlgren III pleaded guilty to filing a false tax return underreporting gains from selling $3.7 million in Bitcoin. As we discussed...more

Lessons from the Hunter Biden Tax Evasion Scandal

Fleurinord Law PLLC on 9/20/2024

Would you risk prison time to avoid paying taxes? That’s a question Robert Hunter Biden, publicly known as "Hunter Biden," may have asked himself when he faced serious tax evasion charges recently. While the case...more

Crypto: Give Unto Caesar What Is Caesar’s

Cadwalader, Wickersham & Taft LLP on 5/22/2024

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

Weekly IRS Roundup April 8 – April 12, 2024

McDermott Will & Emery on 4/16/2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 8, 2024 – April 12, 2024. April 8, 2024: The IRS released Internal Revenue Bulletin 2024-15,...more

Individuos De Alto Patrimonio Reciben Advertencia Del IRS

Foodman CPAs & Advisors on 4/16/2024

El 10 de abril de 2024, como parte de su campaña de la Docena Sucia (“Dirty Dozen”) para 2024, el IRS emitió una advertencia a individuos de alto patrimonio con respecto a tres trampas fiscales diseñadas para ellos por...more

High Net Worth Individuals Get Warning From IRS

Foodman CPAs & Advisors on 4/16/2024

On 4/10/24, as part of its Dirty Dozen Campaign for 2024, the IRS issued a warning to High Net Worth Individuals regarding three tax traps designed for them by dishonest promoters and shady tax practitioners. High Net Worth...more

Bare Knuckle Conservation Easement Brawl Leaves Participants in Limbo

Polsinelli on 3/7/2024

Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more

Millionaires, Corporate Jets and Crypto: IRS Unveils New Enforcement Initiatives

Fox Rothschild LLP on 3/7/2024

Thanks to a dramatic increase in funding courtesy of the Inflation Reduction Act of 2022, the Internal Revenue Service recently announced several new, high-profile enforcement initiatives designed to generate significantly...more

Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent...

Ballard Spahr LLP on 3/5/2024

In this episode, we are joined by Special Agent Jonathan Schnatz, Senior Analyst with IRS Criminal Investigation. Special Agent Schnatz will discuss his work with an international law enforcement and tax compliance group, and...more

Investigations Newsletter: Home Health Care Owner Sentenced to Nine Years in Prison for Medicare Fraud Scheme

ArentFox Schiff on 2/5/2024

Home Health Care Owner Sentenced to Nine Years in Prison for Medicare Fraud Scheme - This week, the owner of a home health company was sentenced to nine years in prison for orchestrating a nearly $2.8 million scheme...more

What Are the Statute of Limitations on an IRS and California Tax Audit?

Allen Barron, Inc. on 11/9/2023

What are the statute of limitations on an IRS audit and a California tax audit? There is a time limit, known as the “statute of limitations“, when the IRS and/or California must complete an audit of your tax returns. It is...more

Data Theft Warning Signs From IRS

Foodman CPAs & Advisors on 10/25/2023

IRS Awareness Campaign for the Summer 2023 focuses on data theft signs and the importance of staying alert against new and ongoing threats of tax-related identity in order to protect the taxpayer and the tax professional. ...more

The IRS is Attacking Abusive Trust Arrangements

Gray Reed on 10/3/2023

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

Weekly IRS Roundup September 18 – September 22, 2023

McDermott Will & Emery on 9/25/2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 18, 2023 – September 22, 2023. ...more

IRS Criminal Investigation Division Is on the Hunt for Malta Pension Plan Participants and Promoters

McDermott Will & Emery on 7/25/2023

There has been a growing trend of US taxpayers contributing non-cash assets, such as appreciated property, securities and cryptocurrency, into Maltese pension plans since the US-Malta Tax Treaty went into effect in 2011....more

Weekly IRS Roundup May 30 – June 2, 2023

McDermott Will & Emery on 6/6/2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 30, 2023 – June 2, 2023....more

2023 Trends in Criminal Tax Enforcement

Foley Hoag LLP - White Collar Law &... on 2/15/2023

This is the second part in our 2023 series examining important trends in white collar law and investigations. Up next: crypto enforcement. The days of decreased IRS enforcement activity may be coming to a close. Although...more

Weekly IRS Roundup December 5 – December 9, 2022

McDermott Will & Emery on 12/13/2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 5, 2022 – December 9, 2022...more

Can You Go to Jail for Not Paying Your IRS Taxes?

Freeman Law on 10/3/2022

Taxpayers routinely ask me if they can go to jail for not paying their federal income taxes. Admittedly, the bar is not that high for felony tax evasion—the government must only prove three elements: (i) willfulness; (ii)...more

New York Alleges Trump Procured Inflated Appraisals for Conservation Easements

Polsinelli on 9/28/2022

On September 21, 2022, the New York State Attorney General Tish James filed a civil lawsuit against former President Donald Trump and the Trump organization alleging fraud and misrepresentation. The Complaint described a...more

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

Oberheiden P.C. on 6/1/2022

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

Tax Court in Brief | Sestak v. Commissioner | Badges of Fraud, Bribery, and Violation of Sharply Defined Public Policy

Freeman Law on 5/6/2022

Tax Litigation: The Week of April 25th, 2022, through April 29th, 2022 Sestak v. Comm’r, TC Memo. 2022-41| April 25, 2022 | Weiler, J. | Dkt. No. 17285-18...more

IRS Criminal Investigation’s Top Ten Cases of 2021

Freeman Law on 2/9/2022

Many (if not most) people and organizations approach a new year by setting new goals or implementing changes. This exercise, however, requires a reflection on the previous year’s events, successes, and failures. And...more

Fraud Penalty Affirmed: In Not-So-Chic Fashion, the Ninth Circuit Upholds Fraud Penalties in Chico

Freeman Law on 1/12/2022

In Chico v. Commissioner, the taxpayers challenged the Tax Court’s assessment of a fraud penalty. The Tax Court had imposed civil fraud penalties against the married taxpayers, finding clear-and-convincing evidence of fraud...more

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