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
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
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
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
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
Last week, the Brazilian Supreme Court (STF) issued decisions on two relevant tax issues: (i) the effective reduction in percentage of the amounts reimbursed to exporters under the Special Regime for the Reintegration of Tax...more
Would you risk prison time to avoid paying taxes? That’s a question Robert Hunter Biden, publicly known as "Hunter Biden," may have asked himself when he faced serious tax evasion charges recently. While the case...more
The U.S. Department of the Treasury on June 17, 2024, confirmed it had formally notified Russia about the suspension of the Convention between the United States of America and the Russian Federation for the Avoidance of...more
Takeaways: •The Office of the Attorney General for D.C. announced a $40 million settlement with Michael Saylor and MicroStrategy, Inc., marking the largest income tax recovery in D.C. history. •The resolution arose from a...more
Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more
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
Tax evasion is as old as tax collection, so it is no surprise that there is tax evasion related to crypto. In a recent case, United States v. Frank Ahlgren III, Federal prosecutors allege that between 2017 and 2019, the...more
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
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
After years of explicitly warning taxpayers that failing to report or underreporting income from transactions involving digital assets would lead to criminal charges, federal prosecutors are now beginning to follow through on...more
On September 8, 2023, the IRS issued a News Release suggesting that FBAR compliance investigations and audits would heat up in the near future. For those unfamiliar with FBARs, federal law requires United States persons to...more
The IRS has recently issued an ominous notice (#IR-2023-126) in which the IRS warns high income US taxpayers and millionaire non-filers that the IRS is targeting them to conduct audits, identify and collect undeclared income...more
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
Have you ever wondered whether you were barking up the wrong tree? That the solution to a problem may be found, not in the approach to which you were already committed and invested, but in an altogether different direction?...more
On 14 February, the EU Council added four jurisdictions (the British Virgin Islands, Costa Rica, Marshall Islands and Russia) to the list of non-cooperative jurisdictions (Annex I) (the “EU Blacklist”)....more
This is the second part in our 2023 series examining important trends in white collar law and investigations. Up next: crypto enforcement. The days of decreased IRS enforcement activity may be coming to a close. Although...more
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
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
On June 21, 2022, the United States Supreme Court agreed to hear a dispute involving split decisions among the circuit courts on non-willful penalties. The Fifth Circuit parted ways with the taxpayer friendly decision of the...more