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 […]
The Internal Revenue Service (IRS) recently launched its highly anticipated Employee Retention Credit Voluntary Disclosure Program (ERC VDP). Under the ERC VDP, eligible businesses can resolve improper ERC claims without liability for interest or penalties. However, filing under the ERC VDP can be risky, and it isn’t the best option […]
Taxpayers who own qualifying offshore accounts and other foreign financial assets have an obligation to disclose these assets to the federal government on an annual basis. As we move into 2024, it is important for high-income and high-net-worth taxpayers to ensure that they have a clear understanding of their reporting […]
If you are facing a federal tax fraud investigation, keeping the investigation out of the public eye can be important for multiple reasons. Not only is it important to protect your personal and professional reputation, but if the investigation is made public, this may give the investigating authorities even more […]
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 […]
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 […]