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Investigations Internal Revenue Service

Oberheiden P.C.

5 Key Considerations for Defending Against Low Income Housing Tax Credit (LIHTC) Fraud Allegations

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Over its nearly 40-year history, the federal low income housing tax credit (LIHTC) program has been both a success story and a target for various forms of fraud. The LIHTC program has been credited with facilitating the...more

K2 Integrity

Don’t Let Cyber Scams Ruin the Holidays: Keep the Holiday Season Festive for Your Organization

K2 Integrity on

“It’s the most wonderful time of the year”—or is it? Unfortunately, it can be the most wonderful time for criminals, who try to prey on financial generosity through scams and frauds. Extra vigilance is needed during the...more

Allen Barron, Inc.

What is Willful Blindness According to the IRS?

Allen Barron, Inc. on

What is willful blindness according to the IRS? How is this important in tax cases involving unreported or under-reported income, disclosure of offshore assets and income, FinCEN Form 114 (more commonly referred to as an...more

Allen Barron, Inc.

Is it Too Late to Correct Past FBARs and File Amended Returns with the IRS?

Allen Barron, Inc. on

Is it too late to correct past FBARs and file amended returns with the IRS? The net is closing in on U.S. taxpayers with unreported or under-reported domestic and offshore income and assets. The IRS has increased audits in...more

Allen Barron, Inc.

The Action Cryptocurrency Investors Need to Take Immediately

Allen Barron, Inc. on

What is the action cryptocurrency investors need to take immediately? What has changed, and why should any digital asset holder or investor pay attention to this game-changing development? Here is the short answer: If you...more

BakerHostetler

First Circuit Adds Another Notch to the IRS’ Belt - Upholds Power To Summons Information from Virtual Currency Exchanges

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Anyone who thought blockchain would keep their cryptocurrency transactions private from the IRS needs to think again. According to the First Circuit’s recent holding, cryptocurrency users do not have a Fourth Amendment...more

Foodman CPAs & Advisors

ERC Voluntary Disclosure Program Re-Opens

On 7/15/24, the IRS announced via Notice IR-2024-212 the re-opening of the ERC (Employee Retention Credit) Voluntary Disclosure Program which will end on 11/22/24. The first ERC Voluntary Disclosure Program ended in March...more

Proskauer - Tax Talks

Proposed Regulations Issued on Reporting Obligations for Basket Contract Transactions

Proskauer - Tax Talks on

On July 12, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations that would classify “basket contract transactions”, which are derivatives (i) with a term...more

Fox Rothschild LLP

IRS Reopens Employee Retention Tax Credit Voluntary Disclosure Program

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The ERC is a legitimate, refundable tax credit designed to help businesses that continued to pay employees while they were shut down because of the COVID-19 pandemic or that experienced a significant decline in gross receipts...more

Mitratech Holdings, Inc

What Triggers an I-9 Audit?

The word “audit” can strike fear in the hearts of HR professionals across the country. With increasing fines, an I-9 audit can turn a small mistake into a big cost....more

Fox Rothschild LLP

IRS Begins Processing Some Employee Retention Tax Credit Claims Filed During the Moratorium

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The Internal Revenue Service has adjusted its moratorium on processing Employee Retention Tax Credit (ERC) claims, announcing last week it will begin processing claims filed between September 14, 2023 and January 31, 2024. In...more

Bracewell LLP

Creating an Army of In-House Investigators

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In its never-ending war on corporate fraud, the Department of Justice (“DOJ”) has just commissioned a private army to fight as never before. On August 1, the DOJ launched a three-year program to provide financial rewards to...more

Allen Barron, Inc.

The Step Doctrine and How it Applies to IRS, State, and California Tax

Allen Barron, Inc. on

It is important to understand the step doctrine and how it applies to IRS audits and state tax investigations, including California tax audits. The "step doctrine" is a concept not directly found in federal or California...more

Womble Bond Dickinson

IRS Continues Aggressive Oversight and Enforcement of Employee Retention Credits

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The Employee Retention Credit (ERC) is a refundable tax credit for businesses whose employees were impacted by the COVID-19 Pandemic. The provisions are set out in § 2301 of the CARES Act and § 3111 of the Internal Revenue...more

Allen Barron, Inc.

US Treasury Says IRS is Focused on Tax Evasion Targeting

Allen Barron, Inc. on

The US Department of the Treasury has recently reinforced the progress on enforcement, specifically how the IRS is focused on tax evasion targeting and the targeting of high-income individuals and entities. The IRS has...more

Allen Barron, Inc.

Willful versus Non-Willful Conduct in the Eyes of the IRS

Allen Barron, Inc. on

What constitutes willful versus non-willful conduct in the eyes of the IRS? Why is this distinction important to the agency, especially regarding international disclosures and taxable events? We are often asked about how...more

DarrowEverett LLP

How IRS Is Cracking Down on Employee Retention Tax Credit Fraud

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The Internal Revenue Service (“IRS”) has recently devoted great attention to detecting, investigating, and prosecuting fraud, particularly as it relates to the Employee Retention Tax Credit (“ERC”) post-COVID. On a webinar...more

BakerHostetler

IRS Enforcement Efforts in Puerto Rico Gaining Steam - Wave of Cases Expected

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Long-awaited enforcement actions may be coming soon for those who took advantage of the lucrative tax breaks offered by the Commonwealth of Puerto Rico without meeting the requirements. Prosecutions may also follow for...more

McDermott Will & Schulte

IRS Criminal Investigation Division Is on the Hunt for Malta Pension Plan Participants and Promoters

There has been a growing trend of US taxpayers contributing non-cash assets, such as appreciated property, securities and cryptocurrency, into Maltese pension plans since the US-Malta Tax Treaty went into effect in 2011....more

Rivkin Radler LLP

Supreme Court Upholds IRS Collections Summons Without Notice

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The Supremes- The Constitution has figured prominently in the news of late. In the days preceding the initial discussions among members of the Administration and the Congressional leadership regarding the debt ceiling,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden’s 2023 Insights – Five Critical Areas for the Year Ahead

The pandemic’s impact may be subsiding, but businesses are encountering new challenges across the globe, including the potential for an economic retrenchment, rising interest rates, shifting regulatory and litigation...more

Sheppard Mullin Richter & Hampton LLP

March 2022 Crypto Enforcement Actions Roundup

In the wake of President Biden’s March 9, 2022, executive order outlining his Administration’s desire to establish a comprehensive federal approach to crypto policy and regulation, federal agencies are continuing to focus on...more

Gray Reed

Guidelines for Protecting Privilege in Tax Cases

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Lawyers, tax or otherwise, understand that privileged information must be protected to encourage a full and frank dialogue that might not occur without confidentiality.1 Tax information, in particular, contains some of the...more

Roetzel & Andress

IRS Asks Major Crypto Exchange For Users’ Identities And Data

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Earlier this month, the United States District Court, Northern District of California approved the Internal Revenue Service’s (IRS) request to execute a “John Doe” summons on the parent company of popular cryptocurrency...more

Rivkin Radler LLP

Cash In Hand, Tax Deferral, Monetized Installment Sales: No, You Can’t Have It All

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Ask the owner of a closely held business to describe their most recently recurring nightmare and you are likely to get an earful regarding the prospect of an increased federal income tax on their profits, an increased federal...more

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