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 SplitThere are several new developments in the Internal Revenue Service’s ongoing campaign to combat false and fraudulent Employee Retention Credit (ERC) claims.
They include an indefinite extension of the agency’s
Continue Reading IRS and Congress Expand Efforts to Address ERC FraudThe IRS has announced a new Voluntary Disclosure Program (VDP) offering businesses a limited-time opportunity to repay improperly claimed Employee Retention Credits at a discount while avoiding penalties and interest. The VDP requires businesses to repay only 80% of the improper credits they received and has an application deadline of March 22, 2024.
Continue Reading New IRS Voluntary Disclosure Program Lets Businesses Repay Questionable Employee Retention Credits at a Discount
In its most recent effort to fight fraudulent and improper Employee Retention Tax Credit (ERC) claims, on December 6, 2023, the IRS announced it will be notifying an initial group
Continue Reading IRS Rejects 20,000 Employee Retention Tax Credit Claims, Plans to Offer New Voluntary Disclosure ProgramThe IRS recently announced that it will offer certain employers an opportunity to withdraw Employee Retention Credit (ERC) claims if they are concerned about their accuracy. Qualifying employers may be
Continue Reading Amid Fraud Investigations, IRS Offers Employers an Opportunity to Withdraw Inaccurate Employee Retention Credit ClaimsWith 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
Continue Reading With April 15 Fast Approaching, DOJ Tax Division Issues Annual Tax Crimes Warning
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
Continue Reading IRS in the Offing? Marinello Limits Tax Obstruction Prosecutions
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
Continue Reading Offshore Accountholders Beware: New DOJ Sentencing Policy for FBAR Cases Is a Game-Changer
The Internal Revenue Service has announced that the nation’s tax season will begin on Monday, January 29, 2018. As is typically the case, the annual opening of tax season is
Continue Reading With Tax Season Fast Approaching, IRS Secures Guilty Plea in High-Profile Tax Case Involving Reality TV Star “The Situation”
August 29, 2017 – Law360
Continue Reading DOJ Offshore Bank Resolution Offers Cooperation Road Map