News & Analysis as of

Criminal Penalties Criminal Liability

Jackson Walker

DOJ Enforcing Criminal Penalties When Employers Fail to Comply

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The Department of Justice (DOJ) has issued a memo indicating a significant policy shift to prioritize immigration enforcement and expand the use of criminal statutes to address illegal immigration. The DOJ will support the...more

BakerHostetler

Wage & Hour Criminality: Wage Theft Now Constitutes Larceny In New York

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Last week, Governor Kathy Hochul signed legislation amending the New York Penal Law in order to allow prosecutors to seek stronger criminal penalties against employers who steal wages from workers. Specifically, employers who...more

Orrick, Herrington & Sutcliffe LLP

DOJ revises corporate enforcement policy applicable to all criminal matters including FCPA cases

On January 17, Assistant Attorney General Kenneth A. Polite, Jr. delivered remarks at Georgetown University Law Center, during which he announced changes to the DOJ’s Criminal Division Corporate Enforcement and Voluntary...more

Freeman Law

IRS Notice 2007-83 Declared Unlawful Under the Administrative Procedure Act

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The Administrative Procedure Act. The Internal Revenue Code (the “Code”) contains over one hundred different civil penalties for various acts or failures to act. For example, Section 6707A requires taxpayers, in certain...more

Oberheiden P.C.

Prescription and Medication Counterfeiting Defense

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21 U.S.C. § 331: Selling Counterfeit Drugs - Under Section 331, it is illegal to sell counterfeit drugs in interstate commerce. Because this includes online sales, the “interstate commerce” element is very easy to...more

Troutman Pepper Locke

Introduction to RICO: What You Need to Know - RICO Report Podcast

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Join Troutman Pepper White Collar and Litigation Partner Cal Stein for a special podcast series, discussing the legal landscape surrounding the Racketeer Influenced and Corrupt Organizations Act (RICO). In this first...more

Gray Reed

Recent Supreme Court Case Provides Possible Pre-Assessment Judicial Review for Onerous Penalties

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The Supreme Court’s recent decision in CIC Services, LLC v. Internal Revenue Service may have significantly expanded taxpayers’ ability to obtain immediate injunctive relief against onerous tax reporting requirement....more

Fisher Phillips

California Employers Face Criminal Liability for Intentional Unpaid Wages Under Newly Signed Law

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California Governor Newsom signed into law yesterday a bill which makes intentional “wage theft” by employers a form of grand theft and thus a felony in the state of California. AB 1003 obviously ups the ante for employers...more

Womble Bond Dickinson

CIC Services, LLC v. Internal Revenue Service: Captive Insurance Wins a Battle, but the War Continues

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On Tax Day, May 17, 2021, in a unanimous opinion authored by Justice Kagan, the United States Supreme Court held that the Anti-Injunction Act ("AIA") does not bar a pre-enforcement challenge to the legality of an IRS-imposed...more

Kerr Russell

Challenge To IRS Notice Does Not Violate Anti-Injunction Act

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In a ruling with implications for retirement and tax planning generally, the U.S. Supreme Court has determined that, in certain circumstances, taxpayers can challenge reporting requirements before complying with the...more

Latham & Watkins LLP

US Supreme Court Allows Challenge to IRS Rule to Go Forward Despite Anti-Injunction Act

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The ruling provides a new avenue for parties to bring pre-enforcement challenges to IRS rules and regulations. Key Points: ..In CIC Services v. IRS, the US Supreme Court allowed a pre-enforcement challenge to an IRS...more

Holland & Knight LLP

U.S. Supreme Court Decision May Pave Way for Future IRS Lawsuits

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The U.S. Supreme Court recently rendered a unanimous opinion holding that the Anti-Injunction Act (AIA) did not block a lawsuit brought by CIC Services against the Internal Revenue Service (IRS), delivering an important...more

McDermott Will & Schulte

Supreme Court Opens Door to APA Challenge of Overreaching IRS Information Reporting Regime

In CIC Services, LLC v. Internal Revenue Service, a unanimous US Supreme Court allowed CIC, a tax advisor, to proceed with a pre-enforcement challenge to the Internal Revenue Service’s (IRS) “reportable transaction” regime....more

Eversheds Sutherland (US) LLP

Supreme Court puts IRS on notice [2016-66] in CIC Services, LLC - The Anti-Injunction Act has its limits

On May 17, 2021, the Supreme Court held that the Anti-Injunction Act (AIA), section 7421(a) of the Code, does not preclude a pre-enforcement challenge to an IRS notice enforced through civil and criminal penalties. The AIA...more

Alston & Bird

Taxpayers Can Strike First: Supreme Court Allows Pre-Enforcement Challenges to Certain IRS Regulatory Actions

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Our Federal Tax Group examines a U.S. Supreme Court ruling that could give taxpayers greater leeway to challenge IRS regulatory schemes before the IRS takes enforcement action....more

Jones Day

Supreme Court Rules Tax Penalty Does Not Bar Pre-Enforcement Regulatory Challenge

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The Supreme Court held that a company may bring a pre-enforcement challenge under the Administrative Procedure Act ("APA") to an IRS reporting requirement backed by a tax penalty. On May 17, 2021, the U.S. Supreme Court...more

Freeman Law

Supreme Court Hands Tax Advisor Big Win in CIC Services, LLC v. IRS

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Federal tax cases against the IRS can be difficult. Even procedurally so. Under the pay-first, litigate-later rule, taxpayers are generally required, prior to filing suit against the United States: (1) to full pay the...more

A&O Shearman

Consob sanction proceedings – The Court of Justice on the right to remain silent

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Individuals who refuse to provide financial market authorities with answers that may establish their liability and trigger administrative sanctions of criminal nature cannot be punished. In Case C-481/19, on 2 February...more

Littler

Protection for Criminal Antitrust Whistleblowers Signed into Law

Littler on

Largely overshadowed by the rise in COVID-19 deaths and the January 6, 2021, siege on the Capitol, the Criminal Antitrust Anti-Retaliation Act of 2019 (“the Act”) became law on December 23, 2020. See 15 U.S.C. § 7a-3....more

Winstead PC

Construction Industry Employers, Take Heed: “Willful” OSHA Violations May Lead to Criminal Penalties

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The U.S. government recently reminded employers that the consequences stemming from worker safety violations are not limited to civil monetary penalties and specific hazard abatement requirements levied by the Occupational...more

Oberheiden P.C.

EKRA Rules, Regulations & Compliance: 5 Tips that Health Care Providers Need to Know

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Most health care providers have at least a basic understanding of the Anti-Kickback Statute. This federal law prohibits providers from offering, paying, soliciting, or accepting any form of “remuneration” for patient...more

K&L Gates LLP

K&L Gates Triage: EKRA - New Fraud and Abuse Considerations for Clinically Integrated Networks

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In this week's episode, Limo Cherian, Carla Dewberry, and Steve Pine discuss EKRA - the 'Eliminating Kickbacks in Recovery Act of 2018,' which introduces new criminal penalties for kickbacks associated with referrals to...more

Foodman CPAs & Advisors

Guilty From The Get-Go In The IRS Updated Voluntary Disclosure Program?

On June 20, 2019, the National Taxpayer Advocate (TA), an independent organization within the IRS that helps taxpayers and protects taxpayer rights, issued a final Report to Congress. A section of the report focused on the...more

Akin Gump Strauss Hauer & Feld LLP

Bahrain’s New Data Protection Law Now in Force

On August 1, 2019, Bahrain’s Personal Data Protection Law (PDPL) (Law No. (30) of 2018) took effect. The PDPL aims to align Bahrain’s data protection framework more closely with global best practices and regulates the...more

Constangy, Brooks, Smith & Prophete, LLP

Amendments To Colorado Wage Act Increase Employers’ Exposure To Criminal And Civil Personal Liability

The Legislature was busy this year, passing a variety of bills that will affect Colorado employers. House Bill 19-1267, entitled Penalties for Failure to Pay Wages, amends the Colorado Wage Act in ways that could be...more

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