A Good Lickin'
The Presumption of Innocence Podcast: Episode 60 - Enforcement Priorities of the Second Trump Administration: Employee Retention Tax Credit
The Presumption of Innocence Podcast: Episode 58 - Enforcement Priorities of the Second Trump Administration: IRS Investigations
Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
UK corporate offence of failure to prevent tax evasion
The Panama Papers - What the Fallout Means for U.S. Companies and Professionals
Foreign Bank Account Reporting and Employment Tax Enforcement: Ronn Owens interviews Steve Moskowitz
The Panama Papers & The Tempo of International Corruption Cases
Lauryn Hill's Tax Evasion a 'Battle for Survival': Lawyer
HMRC has reportedly brought its first-ever corporate prosecution under the failure to prevent the facilitation of tax evasion offence, almost eight years after the legislation was introduced in the Criminal Finances Act 2017....more
In this episode of "The Trial Lawyer's Handbook" podcast series, litigation attorney Dan Small reflects on the wisdom of juries demonstrated in the complex drug smuggling Racketeer Influenced and Corrupt Organizations Act...more
In a significant policy shift, the IRS has revised Form 14457, Voluntary Disclosure Practice Preclearance Request and Application, the cornerstone of its Voluntary Disclosure Practice (VDP), by removing the controversial...more
As an American living abroad, you may have experienced firsthand the challenges of finding a financial institution willing to work with you. Whether it’s for opening a bank account, investing in local markets, securing a...more
Officials at the U.S. Department of Justice have announced plans to eliminate its Tax Division and relocate its attorneys to other divisions within the department. In existence for more than 90 years, the Tax Division is one...more
How many U.S. taxpayers and expatriates may need to file offshore disclosures and FBARs with the IRS? Should those who have not yet filed a disclosure application utilize the VDP (Voluntary Disclosure Program) or a...more
The United Kingdom is set for a step change in the way in which it combats tax evasion. His Majesty’s Revenue & Customs (HMRC) – the UK’s tax, payments and customs authority – has announced plans to adopt a US-style approach...more
What do you need to know about offshore real estate ownership and any associated tax reporting requirements? Are you a U.S. taxpayer or U.S. resident who owns real estate outside of the United States? It may surprise you to...more
The IRS Has Eyes - Having any presence on social media—even sans influencer following or income—can and may be used against you by the IRS. Have you ever Googled yourself? You will likely be shocked at how much...more
In a landmark move, HM Revenue & Customs (HMRC) has announced plans to launch a formal whistleblower award program modelled on the highly successful U.S. Internal Revenue Service (IRS) Whistleblower Program. This initiative...more
Five years and two presidential administrations later, tensions remain — with the IRS and tax credit applicants — over the pandemic-era Employee Retention Tax Credit (ERC). While the IRS has been continuing a Biden-era...more
The Emirate of Dubai in 2024 issued Law No. (1) of 2024 Concerning Tax on Foreign Banks Operating in the Emirate of Dubai. The Law’s passing is an essential step to clarify the applicability of separate tax laws for foreign...more
What’s on the Trump administration’s agenda when it comes to federal investigations? Listen to the first in a series of episodes aimed at answering that question. Former IRS Special Agent Jonathan Schnatz joins host Matt...more
The world is an ever-changing, ever-evolving crucible of financial and other serious challenges for expats and those considering moving abroad, as well as foreign nationals living and working in the United States. Oversight,...more
From Reality TV to Real-Life Tax Fraud: Peter Thomas’ $2.5 Million Scandal - Peter Thomas, best known for his appearances on The Real Housewives of Atlanta, was sentenced on December 19, 2024, to 18 months in federal prison...more
Ten years after its establishment, France’s National Financial Prosecutor’s Office (Parquet National Financier or PNF) has released its 2024 annual report (Report),1 showcasing a year of consolidation and innovation in the...more
Our analysis of financial crime and investigations developments over the past 12 months provides a revealing picture of an increasingly challenging regulatory and enforcement landscape facing businesses around the world. The...more
There was significant legal and regulatory scrutiny across both private and state-owned sectors in Poland in 2024, focusing on business fraud, sanctions compliance, money laundering, and bribery. State-owned enterprises,...more
There has been an increase in enforcement action and strategies relating to cybercrimes, supply-chain related offenses, VAT fraud, corruption, and money laundering. A significant shift has been prompted by the EU Corporate...more
Internal Revenue Service Criminal Investigation (IRS-CI) recently released its Fiscal Year 2024 (FY24) Annual Report, providing insight into the types of crimes the agency is focused upon, as well as the first criminal...more
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
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
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
In 2025, whistleblower regulations are poised for major evolution, reflecting a renewed commitment to transparency and accountability. The Ethics and Compliance Initiative (ECI) 2023 survey revealed a startling statistic:...more
The Guidance to organisations on the offence of failure to prevent fraud, (the Guidance), introduced under the Economic Crime and Corporate Transparency Act 2023 (ECCTA) has finally been published by the U.K. Government. With...more