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
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
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
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
Recent weeks have seen several notable developments in the UK criminal enforcement landscape...more
As announced in the United Kingdom’s Spring Budget for 2024, delivered by the Chancellor of the Exchequer on 6th March, the UK government has published a consultation to seek views on the implementation of the OECD’s flagship...more
The Crypto-Asset Reporting Framework (“CARF”), is the OECD’s flagship tax transparency standard to help combat criminal activity using crypto-assets to evade taxation. The key aspects of the CARF were covered in the article...more
It is no great secret that criminal enforcement in the United Kingdom against corporations has lagged behind our counterparts in the United States and other jurisdictions. In recent years the UK government has introduced a...more
On 19 July 2023, the new convention for the elimination of double taxation (the “New Convention”) between Luxembourg and the United Kingdom (the “Contracting States”) and its protocol were ratified by the Luxembourg Chamber...more
In Short - The Situation: Following years of lobbying by senior prosecutors and other commentators, the UK government seems set to introduce an offence of a corporate failing to prevent economic crime....more
Binance Holdings Limited (Binance), the world’s largest cryptocurrency exchange platform by trading volume, is facing growing legal and regulatory scrutiny across many jurisdictions, signaling increasing pressure on the...more
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
The UK Government has asked the Law Commission to review the law on corporate criminal liability and propose options for reform. Supporters of reform will use recent failures of the UK Serious Fraud Office to prosecute large...more
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
Tax avoidance is the process of manipulating tax rules to reduce the amount of tax payable and obtaining a financial advantage that was never the intention of the legislation. A typical example of tax avoidance involves the...more
Thursday’s weekly unemployment report managed to pull double duty—marking another decrease in the still-high figures (roughly 709k new jobless claims last week, about 47k fewer than the week before) that suggests some cause...more
With effect from December 1, 2020, Her Majesty's Revenue and Customs ("HMRC") ranks ahead of floating charge holders and unsecured creditors with respect to recovering certain pre-insolvency taxes from an insolvent business...more
Corporate criminal offences (CCOs) under Part 3 Criminal Finances Act 2017 (CFA) are increasingly coming under the spotlight of the UK tax authorities. In a 10 February 2020 press release published in response to a Freedom of...more
HMRC’s focus on organisations under the Criminal Finances Act 2017 for failure to prevent tax evasion is making steady progress. The revelation, in very broad terms, of the number of investigations and enquires that it is...more
Draft legislation included in the Finance Bill 2019-2020 will potentially make directors and certain other individuals closely connected to a company jointly and severally liable for a company’s tax liabilities that arise...more
This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including a review of the first year of GDPR enforcement, analysis of...more
A notable feature of the UK tax landscape is the ever-increasing powers available to the UK tax authority, HM Revenue & Customs (“HMRC”), to challenge all forms of tax non-compliance. However, questions have arisen in recent...more
On 9 May 2019, the House of Commons Library published a lengthy report, “Tax avoidance and tax evasion” (the “Report”). The Report summarises some of the government’s key measures to tackle tax avoidance and tax evasion,...more
The latest on Uber’s Friday IPO includes new details on its anticipated pricing, which for now looks to come in at the midpoint of its $44-50/share range [though demand is probably strong enough for the company to shoot for...more
HM Revenue & Customs has provided a timely reminder of the need for organisations with a connection to the United Kingdom to review their prevention procedures regarding the failure to prevent the facilitation of tax evasion...more