The Internal Revenue Service (IRS) routinely targets high-income and high-net-worth taxpayers suspected of using abusive tax shelters to evade federal tax liability. Abusive tax shelters fall into several categories, the broadest of which are the IRS’ “Listed Transactions.” As federal tax audits and investigations targeting Listed transactions can present substantial […]
Category: IRS
The Internal Revenue Service (IRS) is continuing to target Employee Retention Credit (ERC) fraud in 2024. While the ERC was originally intended as a pandemic-era relief program, limited oversight allowed a substantial volume of fraudulent claims, and promoter schemes led many business owners to unknowingly claim credits for which their […]
While the national public health emergency related to the COVID-19 pandemic may have ended in 2023, combating COVID-related fraud remains a top federal law enforcement priority in 2024. The Internal Revenue Service (IRS) is one of several agencies involved in the government’s ongoing response, and IRS Criminal Investigation (IRS CI) […]
On February 21, 2024, the Internal Revenue Service (IRS) announced that it plans to conduct “dozens of audits on business aircraft involving personal use” throughout the year. Citing the IRS’ additional funding under the Inflation Reduction Act, the News Release quotes IRS Commissioner Danney Werfel as stating: “With expanded resources, […]
The Internal Revenue Service (IRS) recently issued a News Release in which it advises employers to resolve any issues with their Employee Retention Credit (ERC) filings by March 22, 2024. This is the deadline to file under the IRS’ limited-time ERC Voluntary Disclosure Program (VDP). But, filing under the ERC […]
Failing to file all necessary returns and pay all federal taxes when due can expose U.S. taxpayers to interest and penalties. This includes not only civil penalties but also criminal penalties in some cases. Interest and civil penalties begin to accrue immediately upon noncompliance, while criminal penalties can result from […]
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 […]
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 […]
Taxpayers that own (or control) offshore bank accounts and other foreign financial assets have a duty to report these assets to the federal government annually. While there are minimum thresholds for taxpayers’ reporting obligations, these thresholds are fairly low—so most high-income and high-net-worth taxpayers will need to comply. Typically, this […]
While the FTX trial has recently been making national headlines, the Internal Revenue Service (IRS), Financial Crimes Enforcement Network (FinCEN), and other federal agencies have been targeting cryptocurrency-related crimes for years. Along with FTX, other exchanges and mixers like Tornado Cash have faced intensive scrutiny as well, and federal authorities […]