April 29, 2020 - Federal Appellate Court Upholds Enforcement of IRS Summons Seeking Information Concerning Law Firm Clients Involved in Foreign Transactions
Federal Appellate Court Upholds Enforcement of IRS Summons Seeking Information Concerning Law Firm Clients Involved in Foreign Transactions
October 10, 2019 - Rev. Rul. 2019-24
(1) Does a taxpayer have gross income under § 61 of the Internal Revenue Code
(Code) as a result of a hard fork of a cryptocurrency the taxpayer owns if the taxpayer
does not receive units of a new cryptocurrency?
(2) Does a taxpayer have gross income under § 61 as a result of an airdrop of a
new cryptocurrency following a hard fork if the taxpayer receives units of new
cryptocurrency?
October 10, 2019 - Frequently Asked Questions on Virtual Currency Transactions
In 2014, the IRS issued Notice 2014-21, 2014-16 I.R.B. 938 (PDF), explaining that virtual currency is treated as property for Federal income tax purposes and providing examples of how longstanding tax principles applicable to transactions involving property apply to virtual currency. The frequently asked questions (“FAQs”) below expand upon the examples provided in Notice 2014-21 and apply those same longstanding tax principles to additional situations.
July 22, 2019 - Justice Department Announces Addendum to Swiss Bank Program Category 2 Non-Prosecution Agreement with Banque Bonhôte & Cie SA
In reaching today’s agreement, Bonhôte acknowledges it should have disclosed additional U.S.-related accounts to the Department at the time of the signing of the non-prosecution agreement.
March 13, 2018 - IRS to end offshore voluntary disclosure program
The Internal Revenue Service today announced it will begin to ramp down the 2014 Offshore Voluntary Disclosure Program (OVDP) and close the program on Sept. 28, 2018. By alerting taxpayers now, the IRS intends that any U.S. taxpayers with undisclosed foreign financial assets have time to use the OVDP before the program closes.
July 6, 2017 - IRS Country-by-Country Reporting
The United States is a member of the Organization for Economic Co-operation and Development (OECD). The OECD recommended country-by-country reporting requirements to address base erosion and profit shifting. The United States issued regulations to require country-by-country reporting by U.S. multinational enterprises (MNEs).
April 25, 2017 - Lois Lerner, Former IRS Official, Remains Relevant On Tax Day
On April 9, 2014, the House Committee on Ways and Means voted to send a letter to the Department of Justice referring former IRS Exempt Organizations Division Director Lois G. Lerner for criminal prosecution. As indicated in the attached letter, the Committee’s nearly three-year investigation uncovered evidence of willful misconduct on the part of Ms. Lerner. Despite this fact, and for what many believe were purely partisan reasons, the prior Administration refused to review Ms. Lerner’s misconduct.”
March 29, 2017 - IRS Targeting Report
March 29, 2017 - IRS still allowed to target political groups, according to watchdog org
A rule in place at the IRS allows the federal agency to delay the applications of non-profit groups looking for tax-exempt status, claims the Washington-based Cause of Action in its report, “A Hidden Cause of the IRS Targeting Scandal.”
March 24, 2017 - Florida Businessman Pleads Guilty To Conspiracy To Commit Tax And Bank Fraud
Padula created two offshore companies in Belize: Intellectual Property Partners Inc. (IPPI) and Latin American Labor Outsourcing Inc. (LALO). He opened and controlled bank accounts in the names of these entities at Heritage International Bank & Trust Limited (Heritage Bank), a financial institution located in Belize. From 2012 through 2013, Padula caused periodic payments to be sent from Demandblox to his accounts at Heritage Bank and deposited approximately $2,490,688.
January 18, 2017 - Southern California Residents Plead Guilty to Hiding Millions of Dollars in Secret Foreign Bank Accounts
In August 2008, Azarian, also opened an undeclared account at Israeli Bank A in Israel, and in May 2009, he closed his undeclared account held at Credit Suisse and transferred the funds to Israeli Bank A. Azarian later partially declared this Israeli Bank A account on his individual income tax returns. At the time of its closure, Azarian’s undeclared account at Credit Suisse held assets valued at approximately $1,903,214.
December 20, 2016 - COURT AUTHORIZES SERVICE OF JOHN DOE SUMMONS SEEKING THE IDENTITIES OF U.S. TAXPAYERS WHO HAVE USED VIRTUAL CURRENCY
A federal court in the Northern District of California entered an order
today authorizing the Internal Revenue Service (IRS) to serve a John D
oe summons on Coinbase
Inc., seeking information about U.S. taxpayers who conducted transactions in a convertible
virtual currency during the years 2013 to 2015.
December 1, 2016 - Court Authorizes Service of John Doe Summons Seeking the Identities of U.S. Taxpayers Who Have Used Virtual Currency
A federal court in the Northern District of California entered an order today authorizing the Internal Revenue Service (IRS) to serve a John Doe summons on Coinbase Inc., seeking information about U.S. taxpayers who conducted transactions in a convertible virtual currency during the years 2013 to 2015. The IRS is seeking the records of Americans who engaged in business with or through Coinbase, a virtual currency exchanger headquartered in San Francisco, California.
August 2, 2016 - California Businessman Charged with Conspiring with Israeli Banks to Hide Income
“Mr. Sarshar stashed millions in secret foreign financial accounts in Israel and then sought to use these accounts to evade his U.S. tax obligations, seeking to cover his tracks along the way,” said Principal Deputy Assistant Attorney General Ciraolo. “The message of this case is clear: There are no safe havens. If you are concealing assets and income in undeclared offshore accounts – or are a banker, an asset manager or otherwise are assisting accountholders in such criminal conduct, your only viable option is to come forward and accept responsibility for your actions. Those who continue to violate U.S. tax laws will be held accountable and pay a heavy price.”
May 12, 2016 - Notice of proposed rulemaking
Treatment of Certain Domestic Entities Disregarded as Separate From Their Owners as Corporations for Purposes of Section 6038A