The head of the Justice Department’s Tax Division has departed for private practice, just as the planned dismantling of the Tax Division was set to take place. Karen Kelly, who
Continue Reading DOJ Tax Division Leader Departs Amid Large-Scale ReorganizationJustice Department Plans to Eliminate Tax Division by End of Summer
Officials at the U.S. Department of Justice have announced plans to eliminate its Tax Division and relocate its attorneys to other divisions within the department. In existence for more than
Continue Reading Justice Department Plans to Eliminate Tax Division by End of Summer
DOJ Seeks Injunction Barring Promotion of Monetized Installment Sales
By Kristy Caron, Nicholas Lyskin, and Adon Solomon
An installment sale occurs when property is disposed of and at least one payment is received after the tax year of the
Continue Reading DOJ Seeks Injunction Barring Promotion of Monetized Installment SalesFBAR: The Eleventh Circuit Holds That Willful FBAR Penalties are Subject to the Eighth Amendment Creating Circuit Split
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 SplitIRS and Congress Expand Efforts to Address ERC Fraud
There 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 FraudNew IRS Voluntary Disclosure Program Lets Businesses Repay Questionable Employee Retention Credits at a Discount
The 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
IRS Rejects 20,000 Employee Retention Tax Credit Claims, Plans to Offer New Voluntary Disclosure Program
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 ProgramAmid Fraud Investigations, IRS Offers Employers an Opportunity to Withdraw Inaccurate Employee Retention Credit Claims
The 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 Fast Approaching, DOJ Tax Division Issues Annual Tax Crimes Warning
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
Continue Reading With April 15 Fast Approaching, DOJ Tax Division Issues Annual Tax Crimes Warning
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
Continue Reading IRS in the Offing? Marinello Limits Tax Obstruction Prosecutions