News & Analysis as of

Internal Revenue Service Tax Liability Tax Fraud

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Vinson & Elkins LLP

Civil Tax Fraud: Should 75 Percent Appear Too Small, Be Thankful the IRS Doesn’t Take It All

Vinson & Elkins LLP on

Mistakes happen, including when it comes to reporting and paying taxes. And for taxpayers and their advisors, those mistakes can lead to costly consequences, as the Internal Revenue Code (“Code”) allows the Internal Revenue...more

Fleurinord Law PLLC

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

Fleurinord Law PLLC on

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

Offit Kurman

Adopting the Moving Van Approach

Offit Kurman on

When it comes to estate taxes, the Internal Revenue Service (IRS) expects all tangible personal property to be properly reported on Schedule F of Form 706. This includes any valuable assets such as art collections, antiques,...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

Gray Reed

News Flash: Tax Fraud by Ex Causes One Woman Lingering Heartache

Gray Reed on

In recent headlines, an Ohio woman has brought a refund suit in district court, seeking recovery of taxes and withholding from the IRS that she claims were based on the improper return filed by her abusive ex-boyfriend. The...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

Polsinelli

Tax Court Strikes out Smoltz and Klesko’s Big K SCE, but Provides Relief for Those Facing Fraud Allegations

Polsinelli on

In the late 1990s, former Atlanta Braves players John Smoltz and Ryan Klesko formed Big K Farms (“Big K”), a partnership that, over the years, acquired approximately 1,500 acres of land in Georgia for around $4 million. From...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

Foodman CPAs & Advisors

Individuos De Alto Patrimonio Reciben Advertencia Del IRS

El 10 de abril de 2024, como parte de su campaña de la Docena Sucia (“Dirty Dozen”) para 2024, el IRS emitió una advertencia a individuos de alto patrimonio con respecto a tres trampas fiscales diseñadas para ellos por...more

Foodman CPAs & Advisors

High Net Worth Individuals Get Warning From IRS

On 4/10/24, as part of its Dirty Dozen Campaign for 2024, the IRS issued a warning to High Net Worth Individuals regarding three tax traps designed for them by dishonest promoters and shady tax practitioners. High Net Worth...more

Polsinelli

Bare Knuckle Conservation Easement Brawl Leaves Participants in Limbo

Polsinelli on

Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more

Ballard Spahr LLP

Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent...

Ballard Spahr LLP on

In this episode, we are joined by Special Agent Jonathan Schnatz, Senior Analyst with IRS Criminal Investigation. Special Agent Schnatz will discuss his work with an international law enforcement and tax compliance group, and...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

Lowndes

Too Good To Last? IRS Halts Processing of ERC Claims

Lowndes on

While not as well-known as the Paycheck Protection Program, the Employee Retention Credit (“ERC”) program was another form of Covid relief provided by the federal government to businesses in 2020 and 2021. The ERC program...more

Gray Reed

IRS Imposes Immediate Moratorium on Employee Retention Credit (ERC) Claims

Gray Reed on

For some time, the IRS has cautioned taxpayers about filing false or fraudulent ERC claims.  More recently, on September 14, 2023, the IRS issued a News Release, IR-2023-169, indicating that it would no longer process ERC...more

Rivkin Radler LLP

Tax Compliance: Self-Assessment, Transparency, and Enforcement

Rivkin Radler LLP on

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

Foodman CPAs & Advisors

GAO Highlights Underreporting, Underpayment And Non-Filing Of Taxes

The U.S. Government Accountability Office (GAO) is known as the U.S. “congressional watchdog,”. GAO is an independent, non-partisan agency that works for Congress by examining how taxpayer dollars are spent and provides...more

BakerHostetler

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

BakerHostetler on

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

Can You Go to Jail for Not Paying Your IRS Taxes?

Freeman Law on

Taxpayers routinely ask me if they can go to jail for not paying their federal income taxes. Admittedly, the bar is not that high for felony tax evasion—the government must only prove three elements: (i) willfulness; (ii)...more

Oberheiden P.C.

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

Oberheiden P.C. on

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

Tax Court in Brief | Sestak v. Commissioner | Badges of Fraud, Bribery, and Violation of Sharply Defined Public Policy

Freeman Law on

Tax Litigation:  The Week of April 25th, 2022, through April 29th, 2022 Sestak v. Comm’r, TC Memo. 2022-41| April 25, 2022 | Weiler, J. | Dkt. No. 17285-18...more

Freeman Law

Fraud Penalty Affirmed: In Not-So-Chic Fashion, the Ninth Circuit Upholds Fraud Penalties in Chico

Freeman Law on

In Chico v. Commissioner, the taxpayers challenged the Tax Court’s assessment of a fraud penalty. The Tax Court had imposed civil fraud penalties against the married taxpayers, finding clear-and-convincing evidence of fraud...more

Freeman Law

The Tax Court in Brief - August 2021 #4

Freeman Law on

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of August 16 – August 20, 2021 - Catlett v. Comm’r, No....more

McDermott Will & Schulte

Key Takeaways | Cryptocurrency Global Tax Enforcement: What Investors and Companies in the Industry Need to Know NOW

During a recent program discussing the latest government enforcement efforts related to cryptocurrency, we spoke with Gary Alford, one of the leading Internal Revenue Service (IRS) agents in their crypto enforcement efforts,...more

McDermott Will & Schulte

[Webinar] Cryptocurrency Global Tax Enforcement: What Investors and Companies in the Industry Need to Know NOW - June 28th, 12:00...

Following the US Internal Revenue Service’s (IRS) announcement of “Operation Hidden Treasure,” companies and individuals should prepare for increased scrutiny of virtual currency transactions. Unveiled in March, the operation...more

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