Tax planning is crucial for high-income individuals. While the Internal Revenue Code imposes substantial tax liability for those who are in the one percent, it also provides opportunities for high-income taxpayers to lawfully reduce the amount they owe. The Internal Revenue Service (IRS) refers to this as “tax avoidance,” and […]
When companies collect payroll taxes from their employees, they hold their employees’ funds “in trust” pending remittance to the IRS. When companies fail to timely remit their employees’ funds held in trust, they can face substantial liability—including liability for the IRS’ trust fund recovery penalty (TFRP). While the IRS often […]
In 2022, IRS Criminal Investigation (IRS CI) identified $5.7 billion in tax fraud and $26.9 billion in other financial crimes. It executed 1,210 warrants and referred 1,837 cases to the U.S. Department of Justice (DOJ) for prosecution. These referrals resulted in a conviction rate of 90.6 percent. These statistics are […]
According to data cited in a recent NPR article, as much as $64 billion of the $800 billion in forgivable loans issued under the Paycheck Protection Program (PPP) may have gone to applicants that didn’t deserve it. As the article also notes, the federal government has up to 10 years […]
Facing scrutiny from IRS Criminal Investigation (IRS CI) is a serious matter. As its name suggests, IRS CI is tasked with uncovering—and assisting in the prosecution of—criminal violations of the Internal Revenue Code (IRC). But, IRS CI’s investigative authority also extends far beyond the IRC, and it routinely announces investigations […]
U.S. taxpayers who own offshore accounts and certain other foreign financial assets have an obligation to disclose these assets to the Internal Revenue Service (IRS)—provided that their value exceeds the IRS’ relatively modest reporting thresholds. Depending on the nature of a taxpayer’s foreign financial assets, this may entail two separate […]
Under the Internal Revenue Code (IRC), interest on unpaid taxes begins to accrue immediately. When taxpayers incur penalties for failure to pay or failure to file, these penalties begin to accrue interest promptly as well. New Underpayment Interest Rates for Federal Taxes and Penalties (Effective January 1, 2023) The Internal […]
The IRS does not view NFTs as vehicles for hidden or untaxable financial activities. Bitcoin, Ethereum, Chainlink, Cardano, Stellar and other cryptocurrencies are assets that exist only digitally on the Internet, but the IRS views them as property for taxation purposes. We have written previously about IRS taxation of gain from […]
The IRS made a large investment in personnel to accelerate investigation of potential abuses of micro-captive insurance transactions. Since 2014, the IRS has put micro-captive insurance arrangements under a microscope to uncover taxpayers and taxpaying entities that may be abusing associated tax benefits. We provided an article in 2019 about IRS settlement […]
Anyone who has received an IRS offer to settle a micro-captive insurance audit should immediately consult an experienced tax lawyer to understand the pros and cons of the offer before any deadline expires. The IRS announced on Sept. 16, 2019, its plan to mail settlement offers to a maximum of […]