News & Analysis as of

Enforcement Actions Income Taxes

Allen Barron, Inc.

The Risk of California FTB Audits is Increasing

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Did you know that the number of California FTB audits is increasing when compared to the trend of IRS audits in 2025? The California Franchise Tax Board, or FTB, has recently invested in advanced data processing systems and...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

Fox Rothschild LLP

On Tax Day, President Names New IRS Chief

Fox Rothschild LLP on

Tuesday, while millions of Americans were busy finalizing their tax returns, the President named a former IRS criminal investigator as the tax agency’s new leader. Gary Shapley, a former IRS special agent who gained...more

Farrell Fritz, P.C.

Relocating? Be Sure to Add the IRS to Your Change of Address Checklist

Farrell Fritz, P.C. on

In a recent decision, the U.S. District Court for the Central District of California held that the Internal Revenue Service (“IRS”) did not violate Internal Revenue Code (“IRC”) Section 7433 or related regulations when it...more

DLA Piper

El Servicio de Impuestos Internos Publica su Catálogo de Esquemas Tributarios 2025

DLA Piper on

Cada año, el Servicio de Impuestos Internos (SII) actualiza la guía denominada Catálogo de Esquemas Tributarios, que contiene un listado de operaciones que pueden ser declaradas elusivas por aplicación de la Norma General...more

DLA Piper

Chile's Internal Revenue Service Publishes It's 2025 Tax Schemes Catalog

DLA Piper on

Each year, the Internal Revenue Service of Chile (SII) updates its Tax Schemes Catalog. This guide contains a list of operations that may be declared elusive by applying the General Anti-Elusiveness Rule. The catalog's...more

Freeman Law

IRS Communication Methods

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With tax season approaching, this blog addresses the ways in which the Internal Revenue Service (“IRS”) will contact you… and the ways in which it will not....more

Rivkin Radler LLP

Not Aware of Your Business Partner’s Tax Situation? Maybe You Should Be

Rivkin Radler LLP on

If you’ve worked with the owners of closely held businesses for even just a few years, you have realized they are only half joking when they complain about having the government as a partner. Consider how much federal, state,...more

Rodemer Kane Attorneys at Law

Tax Fraud: Simple Mistake or Serious Crime?

Taxes. Except for maybe the CPAs and tax professionals, the word alone elicits groans and sighs from even the most cheerful among us. While the necessity of taxes is rarely disputed, navigating the complex world of tax...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

BakerHostetler

No Further Warnings - Prosecutors Bring First Pure Legal Digital Asset Tax Indictment; More Criminal Cases to Come

BakerHostetler on

After years of explicitly warning taxpayers that failing to report or underreporting income from transactions involving digital assets would lead to criminal charges, federal prosecutors are now beginning to follow through on...more

Gray Reed

Release the Kraken Tax Transaction Information

Gray Reed on

On June 30, 2023 the District Court in the Northern District of California granted a petition to enforce the cryptocurrency exchange Kraken to release customer information.  Specifically, Kraken was ordered to produce the...more

Allen Barron, Inc.

IRS Focuses Scrutiny on High-Income Taxpayers, Partnerships and Corporations

Allen Barron, Inc. on

New issues come into focus as the IRS focuses scrutiny on high-income taxpayers, partnerships and corporations, as well as those who promote the abuse of tax rules.  The IRS has formally given notice that it intends to...more

Gray Reed

The IRS is Hiring an Army to Audit Corporations, Partnerships, and High-Income Individuals

Gray Reed on

The IRS has been understaffed for many years, and this has led to a decline in the number of audits conducted.  The personnel shortage has also made it difficult to keep up with the growing complexity of the tax code and to...more

Gray Reed

The IRS is Attacking Abusive Trust Arrangements

Gray Reed on

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

BakerHostetler

New Crypto Payment and Web3 Products Launch; UK Seeks Input on DeFi Taxation; OFAC Fines Crypto Exchange; SEC, DOJ, CFTC Continue...

BakerHostetler on

Multiple Financial Services Firms Announce New Crypto Products - A major U.S. financial services firm recently launched its Crypto Credential product, “a set of common standards and infrastructure that will help verify...more

Polsinelli

Beware, the IRS is Coming: More IRS Audits to Focus on High-Net Worth Individuals and Passthrough Entities

Polsinelli on

After much anticipation, the IRS has finally announced a strategic operating plan to spend the nearly $80 billion in funds that it was allocated through the Inflation Reduction Act. Since this bill was signed, the new IRS...more

Foley Hoag LLP - White Collar Law &...

2023 Trends in Criminal Tax Enforcement

This is the second part in our 2023 series examining important trends in white collar law and investigations. Up next: crypto enforcement. The days of decreased IRS enforcement activity may be coming to a close. Although...more

Snell & Wilmer

SEC Comment Letter Trends and Enforcement Item of Note

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SEC Comment Letter Trends - During the 12 months ended June 30, 2022, the first and second most common comment areas by the SEC were non-GAAP financial measures (also number 1 in 2021 and 2020), followed by management’s...more

Freeman Law

Section 6751(b) Penalty Approval Circuit Split

Freeman Law on

Eleventh Circuit Sides with Ninth Circuit on Section 6751(b) Circuit Split - Introduction: Section 6751(b) and the Timing of Supervisory Approval of a Penalty - The Eleventh Circuit’s decision in Kroner v. Commissioner,...more

McDermott Will & Schulte

Tax That DC?!?! FCA Suit on Residency Brings Business Intelligence Company into the Crosshairs

For the first time since the enactment of the False Claims Amendment Act of 2020, the DC Attorney General’s (AG’s) Office has used its new tax enforcement powers to pursue an alleged personal income tax deficiency. This...more

Gray Reed

IRS Penalty Denied Because of Poor Penmanship

Gray Reed on

Many people, myself included, can sometimes be accused of poor penmanship. As our paperwork becomes more and more electronic, we write less and less down with pen and paper. However, a recent decision from the tax court may...more

Jones Day

Vital Signs: Digital Health Law Update Winter 2022

Jones Day on

Note From the Editors With 2022 well underway, the rapid pace of statutory, regulatory, policy, and industry activities in digital health continues in force. We bring you Vital Signs, a curated, one-stop resource on the most...more

Gray Reed

IRS-Criminal Investigations Counts Down the Top 10 Cases of 2021

Gray Reed on

“The investigative work of 2021 has all the makings of a made for TV movie – embezzlement of funds from a nonprofit, a family fraud ring that stole millions in COVID-relief funds and a $1 billion Ponzi scheme used to buy...more

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