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Tag: White Collar Defense

FARA Enforcement Is No Slam Dunk For Prosecutors

By: Jay R. Nanavati Law360 Expert Analysis – Opinion In the wake of the Mueller investigation and the U.S. Department of Justice Office of the Inspector General’s 2016 “Audit of the National Security Division’s Enforcement and Administration of the Foreign Agents Registration Act,” Attorney General William Barr and DOJ National Security

IRS Issues New Guidance For Offshore Voluntary Disclosures

By: Michael Sardar Tax Stringer April 2019 Edition Download Publication On March 13, 2018, the IRS announced that it would end its long-running Offshore Voluntary Disclosure Program (“OVDP”) on September 28, 2018. With the closure of one of the IRS’s most successful compliance enforcement programs, practitioners were anxious for the IRS

U.S. V. Marc Berger: A Cautionary Tale For Return Preparers

By: Sharon L. McCarthy The CPA Journal February 2019 Edition On December 14, 2018, former CPA Marc Berger was sentenced to eight months in prison after a federal jury convicted him on three counts of aiding and abetting tax evasion for a client. Berger’s fall from grace serves as an important

Reporting Undisclosed Foreign Assets: The Clock Is Ticking

By: Michael Sardar August 2018 Edition The CPA Journal On March 13, the IRS announced that it will close the Offshore Voluntary Disclosure Program (OVDP), effective September 28, 2018. In the announcement, the IRS encouraged taxpayers who need to disclose noncompliant and unreported foreign accounts and assets to come forward before

Pros And Cons Of Voluntarily Disclosing Past Wrongs

By Wendy Abkin, George Abney, and Caroline D. Ciraolo Tax Executive Institute February 2018 TO DISCLOSE OR NOT TO DISCLOSE, THAT IS THE QUESTION Hamlet’s thoughts weighed heavily upon him. Should he suffer the slings and arrows of outrageous fortune, or take arms against a sea of troubles? For the young Prince

Statutory Maximum/Minimum Sentences And Application Of Offense Levels

By Caroline Rule ABA Section of Litigation November 2017 Edition Most federal district court judges are accustomed – even in this age of “advisory” U.S. Sentencing Guidelines (Guidelines or U.S.S.G.) – to sentencing a criminal defendant by first calculating the applicable “Offense Level,” which provides for a range of months of

Using Bitcoin To Buy A Sandwich Could Trigger A Tax Bill

Op-Ed By Bryan C. Skarlatos Featured on CNBC Crypto currencies may have been around for less than a decade, but they are proliferating so quickly that our established tax and regulatory systems can’t keep up. And that could create serious tax problems for those who would join the digital currency revolution.

When Should A Taxpayer Know That A Tax Shelter Is Too Good To Be True?

By Bryan C. Skarlatos & Henry Stow Lovejoy Journal of Tax Practice & Procedure June – July 2017 Edition Taxpayers who have underpaid their taxes can avoid accuracy-related penalties under Code Sec. 6662 by demonstrating that they acted with reasonable cause and in good faith. In general, the most important factor in determining