When seeking to close the tax gap through enforcement, the Internal Revenue Service (IRS) doesn’t solely target taxpayers who have underreported and underpaid their federal tax liability. It also targets those who facilitate tax evasion and tax fraud. Accountants, advisors and promoters can all face heavy-handed enforcement; and, when targeted […]
Category: Tax Crimes
On December 6, 2023, the Internal Revenue Service (IRS) announced that it was sending an “initial round” of 20,000 letters to taxpayers informing them that their Employee Retention Credit (ERC) claims had been denied. According to the IRS’ press release, the letters reflect the agency’s “increased scrutiny of ERC claims in […]
When targeting high-net-worth taxpayers in criminal cases, the Internal Revenue Service (IRS) has several tools at its disposal. One of these tools is its power to seize taxpayers’ property. The IRS does not need to wait for the Justice Department to secure a conviction to seize taxpayers’ property—and this means […]
Charitable donations offer the opportunity to achieve significant tax savings while helping to support valuable causes throughout the United States and around the world. Charitable giving is a key component of most high-income and high-net-worth tax planning strategies, and the Internal Revenue Code expressly allows taxpayers to deduct a percentage […]
On October 19, 2023, the Internal Revenue Service (IRS) announced a limited-time “withdrawal option” for businesses that improperly claimed the Employee Retention Credit (ERC). The ERC is a pandemic-era relief program that allows eligible businesses to claim refundable employment tax credits for the 2020 and 2021 tax years. Technically, the […]
Aiding or abetting the understatement of tax liability is a federal crime. Certified public accountants (CPAs) and advisors accused of aiding and abetting fraudulent tax filings can face steep penalties under 26 U.S.C. Section 6701 and potentially under other federal criminal statutes as well. This raises a crucial question: What does […]
IRS Criminal Investigation (IRS CI) conducts inquiries targeting a wide range of both tax-related and non-tax-related offenses—and these inquiries can present substantial risks for high-asset and high-income taxpayers. This includes not only the risk of substantial liability for back taxes, interest and fines, but also the risk of federal incarceration. […]
In a recent update on the federal government’s ongoing efforts to prosecute Paycheck Protection Program (PPP) and Economic Injury Disaster Loan (EIDL) fraud, we noted that the U.S. Small Business Administration (SBA) has identified 11 “fraud indicators” based on its enforcement efforts to date. As we also noted in the […]
While the Internal Revenue Service’s Criminal Investigation Division (IRS CI) is responsible for investigating federal tax crimes, it doesn’t focus solely on criminal violations of the Internal Revenue Code. IRS CI investigates other financial crimes as well, and it routinely works alongside the Federal Bureau of Investigation (FBI) and the […]
U.S. taxpayers that have failed to meet their filing and payment obligations have various options for resolving these “tax controversies” with the Internal Revenue Service (IRS). However, the specific options that are available in any particular case depend on the circumstances involved. For example, while IRS Criminal Investigation’s (IRS CI) […]