In the first part of this post, we began discussing how federal regulators use non-prosecution agreements (NPAs) and deferred prosecution agreements (DPAs) to resolve various legal compliance concerns. In the tax community, this has particularly been the case with offshore accounts. Indeed, for nearly two years, the Tax Division of […]
Recently, there have been many stories involving people being prosecuted – or assets being seized – due to withdrawals or deposits being conducted at the bank in amounts less than $10,000. Most noteworthy is the example of former House Speaker Dennis Hastert, who was recently indicted for it. These reports […]
We will conclude our two-part post on non-prosecution agreements regarding offshore accounts in next week’s post. This week we will take note of the ongoing story of a serious data breach at the IRS. In early June, the Senate Finance Committee held a hearing on the breach, after hackers gained […]
The Department of Justice has unsealed a 47 count indictment against 14 individuals related to allegations of FIFA corruption, including charges of tax fraud, money laundering, wire fraud, and racketeering. As part of the alleged conspiracy spanning 25 years, the co-conspirators used false consulting agreements to disguise the illicit payment […]
Rothschild Bank AG and Banca Credinvest SA are the two latest Swiss Banks to settle with U.S. authorities as part of the Department of Justice’s ongoing Swiss Bank Program. In exchange for non-prosecution agreements, the banks will pay fines and turn over detailed information about their American clients. Rothschild was […]
In recent years, increased U.S. enforcement of offshore account reporting requirements has not only affected individual taxpayers. Foreign financial institutions have also been deeply affected. Swiss banks, historically a haven for undisclosed accounts, have come under particular scrutiny. And so it was no surprise that Forbes reported this week on […]
In the first part of this post, we began discussing the issue of worker classification for purposes of paying (or avoiding) payroll taxes. The issue of worker vs. contractor has been around for years, but is as timely as ever. As we noted, this is because revenue agencies have been […]
At an annual Offshore Alert conference, the director of the IRS offshore voluntary compliance initiative revealed that the IRS recently issued John Doe summonses to seven more foreign private banks. While he did not reveal which banks the summonses were issued to, he did say that they were not limited […]
IRS Criminal Investigation (CI) released its annual report, which details statistics for the 2014 calendar year, as well as its current enforcement priorities. The report yielded some interesting findings. As expected, the budget cuts that have afflicted the IRS have also affected CI, with the overall number of investigations initiated […]
Worker classification and its connection to payroll taxes is a thread we have been following for quite some time in this blog. In the last few years, tax authorities have put considerable pressure on employers regarding the possible misclassification of employees as contractors in order to avoid payroll tax obligations. […]