News & Analysis as of

Department of Justice (DOJ) Tax Liability

Fleurinord Law PLLC

From Beats to Bills: How DJs Tiësto and Afrojack Were Entangled in a $100M Offshore Tax Scheme

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Spinning the Globe: When the Music Stops, the IRS Listens - Imagine standing on stage in Ibiza, Tokyo, or Miami, spinning beats to millions while pulling in seven figures per gig. That’s the reality for Dutch DJs Tiësto...more

Fox Rothschild LLP

DOJ Seeks Injunction Barring Promotion of Monetized Installment Sales

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An installment sale occurs when property is disposed of and at least one payment is received after the tax year of the disposition. See I.R.C. § 453. Under a standard installment sale, the buyer makes scheduled payments to...more

Fleurinord Law PLLC

Real Housewives Star Peter Thomas’ Payroll Tax Evasion Case: What Every Small Business Owner Must Know

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From Reality TV to Real-Life Tax Fraud: Peter Thomas’ $2.5 Million Scandal - Peter Thomas, best known for his appearances on The Real Housewives of Atlanta, was sentenced on December 19, 2024, to 18 months in federal prison...more

Cadwalader, Wickersham & Taft LLP

2024 Crypto Tax Year in Review

The crypto tax space saw significant developments in 2024. As 2025 ushers in new regulatory shifts (as our colleagues discussed here), tax changes may be on the horizon. In anticipation, this review revisits crypto tax...more

Holland & Hart LLP

the buzz: Cannabis News & Policy Update | February 2025 Special Tax Edition

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Welcome to the buzz: Special Tax Edition. April 15 is just over two months away. This Special Tax Edition includes practical considerations to help you prepare for tax filing season, including: A former DOJ attorney...more

Cadwalader, Wickersham & Taft LLP

First Stand-Alone Crypto Tax Fraud Case Leads to Guilty Plea

On September 12, 2024, the U.S. Department of Justice (“DOJ”) announced that Frank Richard Ahlgren III pleaded guilty to filing a false tax return underreporting gains from selling $3.7 million in Bitcoin. As we discussed...more

Cadwalader, Wickersham & Taft LLP

Crypto: Give Unto Caesar What Is Caesar’s

Earlier this year the U.S. Department of Justice (“DOJ”) brought USA v. Ahlgren, its first crypto case with tax evasion allegations unrelated to another crime, demonstrating the DOJ’s willingness to pursue stand-alone crypto...more

Polsinelli

CPA gets 25 years for Promoting Conservation Easement Deductions

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Judge Batten, Chief United States District Judge for the Northern District of Georgia, handed down lengthy sentences in the first-of-its-kind criminal trial related to syndicated conservation easements (“SCEs”). On January...more

Gray Reed

The IRS is Attacking Abusive Trust Arrangements

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Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more

Cadwalader, Wickersham & Taft LLP

Liberty Global and DOJ Go Head to Head on Economic Substance Doctrine

Liberty Global Inc. ("LGI") and the Department of Justice are in fierce litigation over the application of the economic substance and step transaction doctrines to a transaction for which LGI claimed a dividends received...more

Polsinelli

Conservation Easements: Palpable Fraud or Honest Mistakes? A Federal Jury Returns a Split Verdict

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On September 22, 2023 a federal jury convicted two promoters, CPA Jack Fisher and attorney James Sinnott, in the Department of Justice’s (“DOJ”) first criminal trial over allegedly abusive syndicated conservation easements...more

Rivkin Radler LLP

Tax Compliance: Self-Assessment, Transparency, and Enforcement

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NY’s Almost There- Back in June of this year, New York’s legislature passed a bill that, if enacted, would create the first state-level public database with information regarding the ownership of limited liability...more

McDermott Will & Emery

Can the Government Sue for Tax Debts Outside IRC Procedures?

McDermott Will & Emery on

On June 1, 2023, in United States v. Liberty Global, Inc.[1], the US District Court for the District of Colorado held that the US Department of Justice (DOJ) can assert and seek judgment for federal income tax deficiencies...more

Polsinelli

First Criminal Syndicated Conservation Easement Trial Begins this Week

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Polsinelli’s Government Investigations and Tax attorneys continue to follow the well-known Fisher case, the Department of Justice’s (“DOJ”) first criminal indictment related to syndicated conservation easements. The trial is...more

Miller Canfield

High-Profile Case Highlights Government's Common Law Right to Pursue Tax Deficiencies in Court

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A federal district court ruled in a high-profile case that the Justice Department may rely on common law rather than the statutory notice of tax deficiency procedure in the Internal Revenue Code to assert a federal income tax...more

Troutman Pepper Locke

Antitrust Division Calls on Activision to Do Its Duty to eSports League Players

Troutman Pepper Locke on

On April 3, the Department of Justice's Antitrust Division (DOJ) filed a complaint against and settlement with Activision Blizzard, Inc. (Activision), alleging the company violated Section 1 of the Sherman Act....more

BakerHostetler

IRS Warns: Hundreds of Crypto Criminal Tax Cases Coming Soon; Hiring of 300 Special Agents Means More to Follow

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Takeaways: ..2022 IRS Criminal Investigation Annual Report highlights significant prosecutions and identifies cryptocurrency as an area of top priority heading into 2023. ..Criminal Investigation Chief Jim Lee...more

Freeman Law

Tax Court in Brief | Lamprecht v. Comm’r | Qualified Amended Return and Foreign Banking Reporting

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Tax Litigation:  The Week of August 29th, 2022, through September 2nd, 2022 Sparta Pink Property, LLC v. Comm’r, T.C. Memo. 2022-88 | August 29, 2022 | Lauber, J. | Dkt. No. 12114-20 Pressman v. Comm’r, T.C. Summ. Op....more

Polsinelli

The DOJ and IRS Focus Enforcement on Syndicated Conservation Easements

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Earlier this year, the Department of Justice filed the first criminal indictment of promoters, appraisers and accountants connected to an alleged scheme to create syndicated conservation easements. The move followed increased...more

BakerHostetler

The Tax Man Is Back: IRS Issues First John Doe Summons in 2022 to Major Crypto Platform, Seeking Treasure Trove of Information on...

BakerHostetler on

Key Takeaways: ..The IRS issued its fourth John Doe summons against digital asset platform sFOX, seeking information regarding user identity and transaction activity over $20,000. ..The use of John Doe summonses...more

Oberheiden P.C.

What Tax Preparers Need to Know Before Sitting for an IRS CI Interview

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The Internal Revenue Service’s Criminal Investigation Division (IRS CI) is targeting tax preparers or the ones who prepare tax returns in 2022. IRS CI is focusing its efforts on tax preparers who underreport their clients’...more

Freeman Law

IRS Voluntary Disclosures and Criminal Employment Tax Violations

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Taxpayers who employ workers have obligations under federal law to withhold and remit federal employment taxes to the IRS. In addition to this withholding and payment requirement, federal law also imposes certain reporting...more

Freeman Law

The IRS, Fraudulent Transfers, and Transferee Liability

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Can you be held liable for a tax liability owed by another taxpayer?  Yes, under certain circumstances.  The IRS  uses fraudulent transfer law and “transferee” liability tools to collect unpaid taxes where a taxpayer has...more

Freeman Law

DOJ-Tax Alleges President of We Build the Wall Filed a False Tax Return and Committed Wire Fraud

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Taxpayers who file false tax returns with the IRS can find themselves in hot water.  Indeed, section 7206(1) of the Internal Revenue Code (“Title 26”) makes it a felony to file a false return when the taxpayer knows that the...more

Freeman Law

[Webinar] Freeman Law International Tax Symposium – General Attendee - November 18th - 19th, 8:00 am - 5:00 pm CST

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Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more

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