News & Analysis as of

Tax Evasion Investigations

Hogan Lovells

HMRC brings first prosecution under failure to prevent facilitation of tax evasion laws

Hogan Lovells on

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

Fox Rothschild LLP

Justice Department Plans to Eliminate Tax Division by End of Summer

Fox Rothschild LLP on

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

A&O Shearman

In a nutshell: Key white-collar crime and investigations challenges for in-house counsel in 2025

A&O Shearman on

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

Allen Barron, Inc.

What is Willful Blindness According to the IRS?

Allen Barron, Inc. on

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

Allen Barron, Inc.

Is it Too Late to Correct Past FBARs and File Amended Returns with the IRS?

Allen Barron, Inc. on

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

Allen Barron, Inc.

The Action Cryptocurrency Investors Need to Take Immediately

Allen Barron, Inc. on

What is the action cryptocurrency investors need to take immediately? What has changed, and why should any digital asset holder or investor pay attention to this game-changing development? Here is the short answer: If you...more

Proskauer - Tax Talks

Proposed Regulations Issued on Reporting Obligations for Basket Contract Transactions

Proskauer - Tax Talks on

On July 12, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations that would classify “basket contract transactions”, which are derivatives (i) with a term...more

Allen Barron, Inc.

US Treasury Says IRS is Focused on Tax Evasion Targeting

Allen Barron, Inc. on

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

McDermott Will & Schulte

IRS Criminal Investigation Division Is on the Hunt for Malta Pension Plan Participants and Promoters

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

Foodman CPAs & Advisors

An IRS “John Doe” Summons is a Powerful Weapon that can Puncture Attorney-Client Privilege

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

Goodwin

Release of Names With Interests in Offshore Entities: Ramifications

Goodwin on

A database containing the names of more than 37,000 people with offshore entities and trusts in 10 tax haven jurisdictions was recently released online, providing a powerful investigative tool for regulators, journalists and...more

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