Is it worth turning yourself in? A Minnesota man did and shaved years off his sentence. As DOJ enforcement evolves under the Trump administration, individuals on the edge of exposure must weigh the risks and rewards of self-disclosure. The line between smart strategy and legal misstep has never been thinner.
Continue Reading Self-Disclosure Calculus Remains Complex Under Trump DOJTurmoil continues to roil the highest ranks of the Internal Revenue Service, as the President…
Continue Reading President Names Yet Another Acting IRS CommissionerOn April 17th, the Fifth Circuit Court of Appeals held that an FCC penalty violates…
Continue Reading Another Civil Penalty Falls under Jarkesy – What’s Next?Harvard University’s Tax-Exempt Status in Jeopardy: What It Could Mean for Your Organization
Nonprofit schools and other entities should be prepared to defend their tax-exempt status in the…
Continue Reading Harvard University’s Tax-Exempt Status in Jeopardy: What It Could Mean for Your OrganizationSubscribe to Tax Controversy & Financial Crimes Report
The Latest
Yesterday, while millions of Americans were busy finalizing their tax returns, the President named a former IRS criminal investigator as the tax agency’s new leader. Gary Shapley, a former IRS…
Continue Reading On Tax Day, President Names New IRS ChiefIRS Turns to New ‘John Doe’ Summonses in Continuing Quest to Combat Offshore Tax Evasion
In recent months the Internal Revenue Service (IRS) has started issuing “John Doe” summonses to overseas trust companies and their related entities and vendors to identify clients and obtain their…
Continue Reading IRS Turns to New ‘John Doe’ Summonses in Continuing Quest to Combat Offshore Tax EvasionMatthew D. Lee, Brian C. Bernhardt, and Jonathan M. Wasser co-authored the Bloomberg Tax article, “Employee Retention Credit Claim Resolution Has No End in Sight” on January 29, 2025. View…
Continue Reading Employee Retention Credit Claim Resolution Has No End in SightIRS Provides Additional Extensions for Taxpayers Affected by Terrorist Attacks in Israel
IRS Notice 2024-72, provides relief for individuals and businesses affected by terrorism in Israel.
Continue Reading IRS Provides Additional Extensions for Taxpayers Affected by Terrorist Attacks in IsraelFBAR: The Eleventh Circuit Holds That Willful FBAR Penalties are Subject to the Eighth Amendment Creating Circuit Split
Introduction
For years, FBAR litigants have made the commonsense argument that large willful FBAR penalties, which can exceed the value of the unreported foreign accounts themselves, violate the excessive fines…
Continue Reading FBAR: The Eleventh Circuit Holds That Willful FBAR Penalties are Subject to the Eighth Amendment Creating Circuit SplitLast October, a District Court in Colorado turned the economic substance doctrine on its head. In Liberty Global, Inc. v. US, a District Court granted the Government’s motion for…
Continue Reading Tax Court to Revisit Problematic Economic Substance RulingCue Up Your Summer Movie Watch List: Crypto Reporting Goes From Lampoon to Hero [1]
Summers are the ideal time for movies, baseball, long and winding road trips across the U.S. in search of the perfect family vacation or, just as important, a reasonable crypto…
Continue Reading Cue Up Your Summer Movie Watch List: Crypto Reporting Goes From Lampoon to Hero [1]The IRS has started its own Employee Retention Credit Olympics
Coinciding with the opening day of the Olympic games, the IRS issued IR-2024-198, again stating that it will deny tens of thousands of ERC claims that, according to the…
Continue Reading The IRS has started its own Employee Retention Credit OlympicsOn July 23, 2024, the U.S. Court of Appeals for the D.C. Circuit reversed the U.S. Tax Court in holding that inventory gain recognized by a nonresident alien individual partner…
Continue Reading Partnership Interest Sale Inventory Gain is Not U.S. Source IncomeAbout this Blog
Published by attorneys in the White-Collar Criminal Defense & Regulatory Compliance and Taxation & Wealth Planning practices of national law firm Fox Rothschild LLP, Tax Controversy and Financial Crimes Report reports on the latest developments in all aspects of tax controversy and financial crimes.