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
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 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
With Tax Season Fast Approaching, IRS Secures Guilty Plea in High-Profile Tax Case Involving Reality TV Star “The Situation”
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 accompanied by well-publicized enforcement actions intended to warn potential tax cheats of the perils of filing a false tax return. This year is no different,
DOJ Offshore Bank Resolution Offers Cooperation Road Map
August 29, 2017 – Law360
Justice Department’s Latest Offshore Bank Resolution Confirms Value of Self-Disclosure and Voluntary Remediation by At-Risk Foreign Institutions
The Justice Department revealed its latest offshore bank resolution by announcing that it had entered into a non-prosecution agreement with a Swiss asset management firm called Prime Partners. This means that Prime Partners will not be criminally prosecuted for participating in what the DOJ characterized as a conspiracy to defraud the Internal Revenue Service and
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 to pay federal employment taxes withheld from his employees’ wages. The government alleged that the defendant, Sreedhar Potarazu, an ophthalmic surgeon licensed in Maryland and
In Securities Fraud Case, Prosecutors Allege Novel Money Laundering Scheme to Circumvent FATCA Reporting Obligations
The U.S. Attorney’s Office for the Eastern District of New York has charged four individuals with securities fraud conspiracy for their involvement in fraudulently manipulating the stock of a U.S. company using a traditional “pump and dump” stock fraud technique. See United States v. Chris Messalas et al., No. 17-MJ-321 (E.D.N.Y.). Prosecutors also allege
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 entitled “With the Individual Income Tax Filing Deadline Approaching, Justice Department Warns Willful Violations of Tax Laws Are Criminal,” the Justice Department sounds the warning
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 potential tax cheats. Today the U.S. Attorney for the Western District of North Carolina and the Special Agent in Charge of the IRS Charlotte Field