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Reporting Requirements Tax Liability Tax Evasion

Cadwalader, Wickersham & Taft LLP

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

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

Cadwalader, Wickersham & Taft LLP

Another Step Nearer for CARF in the UK

As announced in the United Kingdom’s Spring Budget for 2024, delivered by the Chancellor of the Exchequer on 6th March, the UK government has published a consultation to seek views on the implementation of the OECD’s flagship...more

Cadwalader, Wickersham & Taft LLP

UK Spearheads Global Commitment to the Crypto-Asset Reporting Framework

The Crypto-Asset Reporting Framework (“CARF”), is the OECD’s flagship tax transparency standard to help combat criminal activity using crypto-assets to evade taxation. The key aspects of the CARF were covered in the article...more

Freeman Law

Section 6751(b) Penalty Approval Circuit Split

Freeman Law on

Eleventh Circuit Sides with Ninth Circuit on Section 6751(b) Circuit Split - Introduction: Section 6751(b) and the Timing of Supervisory Approval of a Penalty - The Eleventh Circuit’s decision in Kroner v. Commissioner,...more

Foodman CPAs & Advisors

How the IRS Uses Social Media to Find Crypto Tax Cheats

Does your Twitter, Reddit, Facebook, Instagram or other social media feed feature photos of your new sports car, boat, fabulous vacation or the beach house that you bought with your crypto gains? Do you also report a low...more

Gray Reed

Non-Willful FBAR Penalties Will be Much Higher in the Fifth Circuit

Gray Reed on

On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account...more

Foodman CPAs & Advisors

Closing A Foreign Bank Account Will Not Solve A Taxpayer’s Disclosure Problem

IRS is interested in U.S. Taxpayer financial accounts everywhere in the world.  If the IRS learns that a Taxpayer has undisclosed reportable accounts or income before a US Taxpayer reports them, the Taxpayer can face serious...more

Foodman CPAs & Advisors

FBAR Penalties: Is it per Account or per Violation?

U.S. Taxpayers (includes a citizen, permanent resident, corporation, partnership, limited liability company, trust and estate) are required to file a Report of Foreign Bank and Financial Accounts (FBAR) if they have...more

Foodman CPAs & Advisors

Indirect linkages to Tax Havens

Foodman CPAs & Advisors on

The U.S. income tax system is based on the idea of voluntary taxpayer compliance. It is the taxpayer’s responsibility to report all reportable worldwide income. Some people attempt to evade paying taxes by failing to report...more

Lowndes

Don’t Forget to File Your Foreign Bank Account Return

Lowndes on

If you have a foreign bank account (or signatory authority on a foreign bank account), you are required to file a Form 114 (commonly called an FBAR) if at any point during the calendar year the combined balance in all of your...more

Foodman CPAs & Advisors

The “J5” is on to Cryptocurrencies

The Organisation for Economic Co-operation and Development (OECD) issued a “call to action” for countries to do more to tackle enablers of tax crimes. The result of this “call to action” was the establishment of an...more

Burr & Forman

IRS Announces End to Foreign Bank Account Disclosure Program: What Can You Do Now If You Still Have Unreported Foreign Bank...

Burr & Forman on

The IRS recently announced it will be shutting down its successful Offshore Voluntary Disclosure Program (OVDP) for unreported foreign bank accounts and income. The program will end September 28, 2018. Under the OVDP, first...more

Butler Snow LLP

U.S. Internal Revenue Service Cancels Offshore Amnesty Program

Butler Snow LLP on

The U.S. Internal Revenue Service has just announced that it will end the Offshore Voluntary Disclosure Program (“OVDP”) on 28 September 2018. ...more

Carlton Fields

A Day Of Reckoning For Recalcitrant Taxpayers?

Carlton Fields on

Following disclosures by UBS whistleblower Bradley Birkenfeld, the IRS launched an aggressive enforcement campaign against undeclared offshore income and financial accounts in 2009. Over time, it has offered a series of...more

Foodman CPAs & Advisors

¿Será la pregunta para el año 2017: ¿tiene cuentas financieras extranjeras?

Desde la crisis financiera mundial que comenzó en el 2007, los contribuyentes Estadounidenses e Internacionales han estado bajo un escrutinio creciente. El sistema financiero ha sido fuertemente regulado y monitoreado de...more

Foodman CPAs & Advisors

Will the question for the Year 2017 be: Do you have Foreign Financial Accounts?

Since the Global Financial Crisis that began in 2007, domestic and international Taxpayers have been under increasing scrutiny. The financial system has been heavily regulated and closely monitored. In addition, the US Tax...more

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