With April 15 just around the corner, the Justice Department’s Tax Division has issued its annual public warning to would-be tax cheats. It is no secret that the Justice Department and Internal Revenue Service significantly ramp up their publicity campaigns regarding tax prosecutions in the weeks leading up to April 15, in an attempt to
Conservation Easements: A Year End Review
The IRS has been cracking down on conservation easement transactions for over ten years. Nevertheless, taxpayers have continued to claim charitable contribution deductions attributable to the donation of conservation easements and promoters have continued to assemble investments utilizing conservation easement charitable deductions. The IRS began focusing on syndicated conservation easement transactions when it issued Notice
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
Offshore Bankers Beware: Justice Department Secures First-Ever Criminal Conviction for Violating FATCA
In a move sure to send shock waves through the offshore banking community, the Justice Department yesterday announced its first criminal conviction for violating the Foreign Account Tax Compliance Act (FATCA). Adrian Baron, the former Chief Business Officer and Chief Executive Officer of Loyal Bank Ltd, an offshore bank with offices in Budapest, Hungary and
Look Out, Tax Zapper Users: Feds Join State-Level Crackdown
August 23, 2018
Articles
Law360
Two weeks ago federal prosecutors announced criminal tax charges against the owners of five Chicago-area restaurants as part of an ongoing federal investigation into the underreporting of gross receipts using sales suppression software. The charges allege that the defendants willfully avoided paying the full amount of
In Wake of New Policy Against “Piling On,” DOJ and SEC Announce Corporate FCPA Resolution
Last month we wrote about the Justice Department’s new corporate resolution policy, which is intended to curb the practice of multiple government authorities imposing separate punishments on a corporate defendant for the same underlying conduct. Employing a football metaphor, Deputy Attorney General Rod Rosenstein explained that the intent of the new policy was to prevent
The Justice Department’s New Corporate Resolution Policy: An End to ‘Piling On’?
By Charles A. De Monaco, Matthew D. Lee and Jana Volante Walshak
Deputy Attorney General Rod Rosenstein unveiled a new Justice Department policy for resolving major corporate investigations last month at a speech to the New York City Bar White Collar Crime Institute.
The new policy encourages coordination among Justice Department components and other enforcement
Offshore Tax Evasion Rounds Out IRS Annual “Dirty Dozen” for 2018
The Internal Revenue Service has issued a warning to taxpayers about avoiding taxes by hiding money or assets in unreported offshore accounts, a tax scam that remains on the annual “Dirty Dozen” for 2018. Offshore tax compliance has been a major focus for the IRS in recent years, and taxpayers should remain wary given the
Offshore Accountholders Beware: New DOJ Sentencing Policy for FBAR Cases Is a Game-Changer
The Justice Department’s Tax Division has recently announced a major policy shift that will invariably result in longer jail sentences for individuals convicted of failing to report their offshore bank accounts on the FBAR form. Since 2009, the Justice Department and Internal Revenue Service have aggressively prosecuted individuals with secret offshore bank accounts, and the