The Internal Revenue Service (IRS) recently released two end-of-year reports highlighting its enforcement efforts during the 2024 fiscal year. In the IRS’s own words, these reports reflect the agency’s “global reach” and “billion-dollar impact” and “outlin[e] key milestones in criminal investigations . . . and advancements in digital modernization that […]
Category: Tax Crimes
Understanding FinCEN’s Beneficial Ownership Reporting Requirements (and the Risks of Non-Compliance)
In the summer of 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) launched a communications campaign “to educate the small business community about new beneficial ownership reporting requirements.” For existing companies, the obligation to file beneficial ownership reports with FinCEN took effect on January 1, 2024. For companies […]
The Internal Revenue Service’s Criminal Investigation Division (IRS CI) conducts investigations focused on all forms of criminal tax evasion and tax fraud. But, its enforcement jurisdiction is also much broader, and it routinely works with the U.S. Department of Justice (DOJ) and other federal authorities to substantiate charges for a […]
For high-income and high-net-worth U.S. taxpayers who are at risk of facing criminal prosecution due to willful tax law violations, making a voluntary disclosure to IRS Criminal Investigation (IRS CI) can facilitate a favorable resolution that avoids formal charges. But, making a voluntary disclosure presents its own risks—and it isn’t […]
The Voluntary Disclosure Practice (VDP) provides an avenue for high-income and high-net-worth taxpayers to resolve significant federal tax controversies without facing criminal prosecution. Administered by IRS Criminal Investigation (IRS CI), the VDP is a long-standing program that allows eligible taxpayers to mitigate their exposure and settle with the IRS—provided that […]
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 […]
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 […]