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 […]
Category: IRS
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 […]
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 news release, the Internal Revenue Service (IRS) announced that it intends to shift its focus to targeting wealthy individuals and business partnerships beginning in fiscal year (FY) 2024. The news release also identifies three specific “priority areas” in which the IRS intends to focus its enforcement efforts […]
On September 8, 2023, the Internal Revenue Service (IRS) announced a “sweeping effort” to enhance its tax collection and enforcement efforts. Among other strategies, the announcement states that the IRS intends to “shift attention to wealthy from working-class taxpayers” while also placing greater emphasis on enforcing partnerships and partners’ tax […]
When targeting taxpayers for fraud and other crimes, the Internal Revenue Service (IRS) has various investigative tools at its disposal. One of these tools is the summons. The IRS routinely issues summonses in order to obtain information in furtherance of its enforcement efforts, and these summonses can present significant risks […]
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 […]
For U.S. taxpayers who are behind on their federal reporting and payment obligations, voluntary disclosure provides an opportunity to resolve their issues with the IRS. However, submitting a voluntary disclosure isn’t an option in all scenarios, and when it is an option, it is not without risks. As a result, […]