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The Presumption of Innocence Podcast: Episode 44 - A Recipe for Litigation: The Simmering Conflict Surrounding ERC Claims
The U.S. Department of Justice (DOJ) and the IRS have issued a John Doe summons targeting Trident Trust and related companies in three federal court cases. This development has significant implications for clients of Trident...more
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
The IRS issued a news release today announcing a continued and more focused use of Artificial Intelligence (AI) to audit partnerships, large corporations and alleged tax shelter promoters. The news release follows...more
In a recent ruling, a California federal judge held that Kraken, an online cryptocurrency exchange program, has to turn over user information to the IRS as a result of a John Doe summons originally served on Kraken in 2021....more
Since at least 2016 the IRS has been ferreting out taxpayers who failed to report their taxable gains from cryptocurrency transactions by issuing John Doe summonses to crypto exchanges and dealers. A John Doe summons enables...more
On September 21, 2022, the U.S. District Court for the Southern District of New York granted the IRS’s ex-parte motion for leave to serve a John Doe summons to M.Y. Safra Bank after the IRS’s investigation into digital asset...more
Exchange Reaches Agreement to Sell Assets; New Crypto Products Launch - In a press release this week, Voyager Digital, a cryptocurrency exchange that recently filed for Chapter 11 bankruptcy, announced that it selected the...more
Key Takeaways - ..A court approved the issuance of a John Doe summons by the IRS to a bank aimed at identifying individuals who are potentially avoiding their income tax obligations relating to cryptocurrency...more
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
On August 15, 2022, the United States District Court for the Central District of California authorized the IRS to serve a “John Doe” summons on Ox Labs Inc., a cryptocurrency prime dealer doing business as SFOX....more
On August 15, 2022, the United States District Court for the Central District of California authorized the IRS to serve a “John Doe” summons on Ox Labs Inc., a cryptocurrency prime dealer doing business as SFOX. ...more
Cryptocurrency and digital assets have kept the courts and regulators busy as digital assets continue to pose new questions and challenges for anyone involved in their sale, trade or development. The following trends have...more
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
The IRS knows it has a problem, in that it knows there are far more cryptocurrency transactions than are being reported on tax returns. The IRS may also get an $80 billion increase in funding for enforcement that will help...more
If you’ve engaged in cryptocurrency or other virtual currency transactions worth $20,000 in any one year between 2016 and 2020, the IRS wants to hear from you. The IRS believes thousands of taxpayers are not telling the...more
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
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
The Internal Revenue Service (IRS) has scored another significant victory in its rapidly increasing virtual currency tax enforcement efforts. On May 5, 2021, the US District Court for the Northern District of California...more
The IRS has several tools in its arsenal to encourage compliance and audit and enforce those it believes are failing to comply. One of the most powerful tools is the John Doe summons. A regular IRS summons seeks information...more
US law enforcement continues to make no secret of their efforts to work closely with experts and overseas partners to prosecute those involved in virtual currency transactions who attempt to rely on its purported anonymity to...more
The Internal Revenue Service (IRS) is stepping up its virtual currency enforcement, and taxpayers who have engaged in a cryptocurrency transaction should immediately assess any potential tax implications as the IRS has...more
An individual that provides information to an attorney may normally assume that the information provided to the attorney will be kept confidential under the attorney-client privilege. That said, according to the Internal...more
IRS-Criminal Investigation (IRS-CI) is a federal agency department specifically authorized to investigate and prosecute federal income tax crimes. IRS-CI uses data analytics such as models, algorithms, and the millions of...more
On July 1, 2019, President Trump signed the Taxpayer First Act (“Act”), which includes a host of important expanded taxpayer protections ranging from adjustments to criminal tax seizures, to John Doe summonses, to the...more
Court rules that a "John Doe" summons to obtain confidential client records from a law firm isn’t barred by attorney-client privilege. On May 15, 2019, a district court in the Western District of Texas held that the...more