Dashing any thought that they were taking a hiatus from investigating and prosecuting taxpayers with secret offshore bank accounts and the bankers that helped them, the Justice Department and Internal
DOJ’s Prosecution of Health Care Exec Illustrates Unique Intersection of Securities & Employment Tax Fraud Schemes
In a recent criminal prosecution of a medical doctor/entrepreneur for defrauding his company’s shareholders, the government employed a novel theory of securities fraud premised, in part, upon the defendant’s failure
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With Tax Day Nearly Behind Us, Justice Department Pivots to Warnings About Employment Tax Violations
Following a relentless flurry of press releases announcing criminal charges against tax evaders in the run up to today’s tax filing deadline (see here, here, and here),
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On the Eve of Tax Day, Justice Department Warns That Tax Evaders Will Face Prison Time
With only four days remaining until “Tax Day,” the Justice Department’s well-publicized campaign to deter potential tax evaders continues with more stern warnings to taxpayers. In a bleak press release
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As Tax Day Approaches, Justice Department and IRS Turn Up Heat on Potential Tax Cheats
With less than two weeks until the April 18 deadline for filing individual federal income tax returns, the Justice Department and Internal Revenue Service are issuing stern warnings to
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John Doe Summonses: A Key IRS Tool Against Tax Evasion
The Internal Revenue Service continues to make frequent use of a relatively unknown information-gathering tool in its nearly decade-old crusade against offshore tax evasion: the “John Doe” summons. A John
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California District Court Finds Failure to File FBARs was Willful Despite Application for Voluntary Disclosure Program
The Bank Secrecy Act requires U.S. taxpayers to file FBARs with the U.S. Treasury disclosing any interest in, or signature authority over, foreign financial accounts with assets in excess of
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IRS Announces 13 Issues Targeted Under its New Audit Campaigns
On January 31, 2017, the IRS announced the initial rollout of its new audit strategy and identified 13 specific issues (campaigns) it will be targeting. The IRS is moving toward
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Justice Department Sends Stern Warning to Employers With Continuing Crackdown on Employment Tax Fraud
Ensuring that employers collect and pay over to the Internal Revenue Service taxes withheld from their employees’ wages is one of the highest priorities of the Justice Department’s Tax Division.
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A Federal Crackdown On Tax Zapper Software
In December, the Justice Department announced criminal charges against John Yin, a software salesman who worked for a Canadian company that sells point of sale (POS) software programs that enabled
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