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Reporting Requirements Internal Revenue Service Enforcement Actions

Mayer Brown

IRS-CI Announces a New Initiative to Enhance BSA Information-Sharing with Financial Institutions

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On March 28, 2025, the Internal Revenue Service (“IRS”)’s criminal investigative arm, IRS Criminal Investigation (“IRS-CI”), announced that it would be implementing a new program called CI-FIRST (Feedback in Response to...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

DLA Piper

Blockchain and Digital Assets News and Trends – January 2025

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This periodic bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets. While the use cases for blockchain...more

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – January 2025

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....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

A&O Shearman

Announcement of new DOJ Whistleblower Policy

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On March 7, 2024, Deputy Attorney General Lisa Monaco announced a new 90-day pilot program at the Department of Justice (DOJ) to incentivize whistleblowers. The program is inspired by and generally follows similar programs...more

Gray Reed

Release the Kraken Tax Transaction Information

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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

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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

Lerch, Early & Brewer

Tenth Circuit Affirms Deficiencies, Penalties for Offshore Income

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Harrington v. Commissioner - In Harrington v. Commissioner of Internal Revenue, George S. Harrington (Harrington) challenged tax deficiencies and fraud penalties assessed for tax years 2005 through 2010. Originally...more

Freeman Law

Section 6751(b) Penalty Approval Circuit Split

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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

Gray Reed

Non-Willful FBAR Penalties Will be Much Higher in the Fifth Circuit

Gray Reed on

On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account...more

McDermott Will & Emery

Finding John Doe, Part II: IRS Secures Another Victory to “Root Out” Virtual Currency Tax Noncompliance

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

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2020 Insights

Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more

Ballard Spahr LLP

IRS CI Highlights International Efforts to Tackle Cryptocurrency Abuse, Money Laundering and Tax Evasion

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ABA Tax Fraud Panel to Discuss IRS CI and Crypto Criminals - The Internal Revenue Service – Criminal Investigation (IRS CI) has made it clear that it is focusing on the abuse of digital currencies to further tax evasion,...more

Hogan Lovells

IRS Renews Focus on Cryptocurrency-Related Offenses

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The Internal Revenue Service (IRS) has signaled for years that it would eventually bring enforcement actions against individuals who failed to report cryptocurrency gains. It appears that “eventually” is over and that those...more

Jones Day

IRS Summons for Law Firm Client Data Is Enforceable

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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

Foodman CPAs & Advisors

Banquero Irá a la Cárcel por FATCA

El 11 de Noviembre del 2018, el Departamento de Justicia de los EE. UU. (“DOJ”) informó que el banquero Adrian Baron, el ex Director de Negocios y ex Director Ejecutivo de Loyal Bank Ltd, un banco “off-shore” con oficinas en...more

Foodman CPAs & Advisors

Banker will go to jail over FATCA

On September 11, 2018, the US Department of Justice (DOJ) reported that banker Adrian Baron, the former Chief Business Officer and former Chief Executive Officer of Loyal Bank Ltd, an off-shore bank with offices in Budapest,...more

Akin Gump Strauss Hauer & Feld LLP

Developments in Cryptocurrency in 2018

• The U.S. Securities and Exchange Commission (SEC) staff made official statements regarding when a token may or may no longer be a security • The SEC continued to bring actions related to cryptocurrency offerings against...more

Foodman CPAs & Advisors

El IRS está pendiente al Cripto

El Jefe de Investigación Criminal del IRS, Don Fort, declaró recientemente: "Es posible utilizar Bitcoin y otras Criptomonedas de la misma manera que las cuentas bancarias extranjeras para facilitar la evasión de impuestos"....more

Carlton Fields

A Day Of Reckoning For Recalcitrant Taxpayers?

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Following disclosures by UBS whistleblower Bradley Birkenfeld, the IRS launched an aggressive enforcement campaign against undeclared offshore income and financial accounts in 2009. Over time, it has offered a series of...more

Latham & Watkins LLP

Top 10 Foreign Bank Account Reporting (FBAR) Mistakes (And How to Fix Them)

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While FBAR reporting rules are frequently misunderstood, US persons have several options to correct mistakes, before the government learns of the non-compliance. June 30th is the annual deadline for filing a Foreign...more

Nossaman LLP

Should You Participate in the IRS Offshore Voluntary Disclosure Program?

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2014 marked a significant increase in the enforcement efforts by the IRS and Department of Justice against non-compliant U.S. taxpayers who failed to report their off-shore bank accounts and earnings.  Grand Jury proceedings...more

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