On January 12, 2021, please join members of Fox’s Tax Controversy team for a review of recent developments in federal tax controversy and civil and criminal tax enforcement, as well as a look ahead at what 2021 may hold. Matthew D. Lee, Jerald David August and Vivian Hoard will review recent developments in federal
IRS Ramping Up Cryptocurrency Enforcement Efforts With “Educational” Letters
The Internal Revenue Service announced today that it has begun mailing what it calls “educational letters” to taxpayers with cryptocurrency transactions who potentially failed to report income and pay the resulting tax from such transactions, or did not report their transactions properly. The IRS started sending these letters to taxpayers last week. By the end
Joint Chiefs of Global Tax Enforcement Mark One Year Anniversary of J5
Earlier this month, the five leaders of the Joint Chiefs of Global Tax Enforcement (known as the “J5”) met in Washington to commemorate the one-year anniversary of the formation of the J5 organization and to announce their first year results. The J5 consists of the leaders of tax enforcement agencies in five countries: Australia, Canada,
Internal Revenue Service Reveals Results of Two-Week Employment Tax Compliance Campaign
Yesterday the IRS announced the results of a nationwide two-week “education and enforcement campaign” regarding employment tax compliance. For several years, the IRS has made employment tax compliance a top enforcement priority, on both the civil and criminal sides. With payroll taxes withheld from employee wages accounting for nearly 72 percent of all tax revenue
Fox Rothschild Attorneys to Speak at Federal Bar Association’s 2019 Tax Law Conference
Fox attorneys Ian M. Comisky and Matthew D. Lee will be speaking on criminal tax enforcement panels at the Federal Bar Association’s 2019 Tax Law Conference to be held on March 7-8, 2019, in Washington, D.C.
Ian will be leading a panel entitled “International Hot Topics in Tax Enforcement” which will seek to answer this
Tax Evaders Beware: IRS-Criminal Investigation Is Hiring
With its special agent ranks significantly depleted after years of budget cuts, the Criminal Investigation Division of the Internal Revenue Service announced this week that it is hiring new special agents. IRS-CI is responsible for investigating potential criminal violations of the tax laws and related financial crimes, and it currently has barely 2,000 special agents
Despite Closure of OVDP, Offshore Tax Evasion Crackdown Marches On
On September 29, 2018, the Internal Revenue Service closed for good the long-running Offshore Voluntary Disclosure Program (OVDP), its hugely successful tax amnesty program for undisclosed offshore financial assets. Since March 2009, the IRS has maintained an offshore voluntary disclosure program in some form or fashion, and more than 56,000 taxpayers have taken advantage of
IRS in the Offing? Marinello Limits Tax Obstruction Prosecutions
Ian M. Comisky and Matthew D. Lee have authored a Journal of Taxation article entitled “IRS in the Offing? Marinello Limits Tax Obstruction Prosecutions.” In their article, Ian and Matt write that its recent decision in Marinello, the U.S. Supreme Court dealt taxpayers a rare win by significantly constraining the government’s ability to employ
IRS Reminds Taxpayers to Report Virtual Currency Transactions
With “tax day” fast approaching, the Internal Revenue Service on Friday reminded taxpayers that income from virtual currency transactions is reportable on their income tax returns. As we have previously reported, the IRS has for some time been focusing significant attention on tax compliance with respect to virtual currency transactions. Last year, the IRS prevailed
Charles Rettig – From Private Practice to President Trump’s Nominee for IRS Commissioner
The White House released a statement on February 8, 2018 that President Trump nominated Charles Rettig as the new Commissioner of Internal Revenue Code for the remainder of a five year term that began in November 2017. Unlike other recent presidential nominees that may have ignited fierce debate among political parties, Rettig’s nomination has been