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Internal Revenue Code (IRC) Criminal Prosecution

McDermott Will & Emery

Action Steps Following the Largest-Ever IRS Data Breach

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On January 29, 2024, Charles E. Littlejohn was sentenced to five years in prison for committing one of the largest heists in the history of the federal government. Littlejohn did not steal gold or cash, but rather,...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

Freeman Law

Treasury Issues Proposed Regulations on IRS Appeals Procedures

Freeman Law on

Taxpayers routinely resolve their tax controversy matters without resort to litigation.  Indeed, good tax professionals will often seek to avoid costly and time-consuming litigation, if possible, by utilizing various...more

Freeman Law

IRS Voluntary Disclosures and Criminal Employment Tax Violations

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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

IRS Criminal Investigation’s Top Ten Cases of 2021

Freeman Law on

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

Latham & Watkins LLP

DOJ Announces Policy Changes to “Invigorate” Efforts to Combat Corporate Crime - Japanese Version

Latham & Watkins LLP on

今回の米国司法省の政策変更において、司法省は個人の責任に一層の重点を置き、また企業の過去の違法行為に対しては包括的な評価を行い、さらに企業との司法解決に対してはより厳格な対応をすることとなる - 2021年10月28日、米国司法省 (United States Department of Justice、以下「DOJ」)...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

Freeman Law

Can You Go To Jail for Failing to Disclose Virtual Currency on a Tax Return or as Part of an Offer for a Collection Alternative?

Freeman Law on

Virtual currency, such as Bitcoin, continues to be a topic of interest for the IRS. Indeed, for the 2019 tax year, the IRS added for the first time a unique question to Schedule 1, Additional Income and Adjustments to...more

Bracewell LLP

New Requirements for Deducting Payments to Governmental Entities

Bracewell LLP on

Section 162(f) of the Internal Revenue Code of 1986 (the Code), as amended by the Tax Cuts and Jobs Act (the TCJA), limits the federal income tax deductibility of certain payments made to a government or governmental entity,...more

Butler Snow LLP

U.S. Internal Revenue Service Updates Voluntary Disclosure Procedures

Butler Snow LLP on

The U.S. Internal Revenue Service has finally updated its voluntary disclosure procedures following the closure of the Offshore Voluntary Disclosure Program (the “OVDP”) earlier this year. The updated procedures will apply to...more

Dorsey & Whitney LLP

The Supreme Court - March 22, 2018

Dorsey & Whitney LLP on

The Supreme Court of the United States issued two decisions yesterday: Marinello v. United States, No. 16-1144: Petitioner Carlo Marinello was indicted in 2012 for violating criminal tax laws following investigations...more

Bowditch & Dewey

IRS and States Crack Down on POS Systems: Zapper Software

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

Foodman CPAs & Advisors

First FATCA Conviction!

On May 9, 2016, the Department of Justice (DOJ) announced its first FATCA conviction. It appears to be the beginning of criminal prosecutions by the DOJ against apparent or alleged violations of FATCA reporting requirements....more

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