Streamlined Disclosure In U.S. v Brian Nelson Booker: A Former CPA Sets A Dubious Precedent
By Sharon L. McCarthy The CPA Journal March 2020 Edition Brian Nelson Booker has the dubious distinction of being the first person criminally charged by the Department of Justice (DOJ) with allegedly making false statements in connection with the IRS’s Streamlined Domestic Offshore Program (SDOP). The former CPA is now a
Lessons Learned From Getting To Not Guilty
By Sharon L. McCarthy and Jay R. Nanavati For the Defense December 2019, Vol. 4, Issue 4 Every criminal defense attorney knows that being indicted is a life-changing event for a client. In many cases, white-collar clients have never even been issued a traffic ticket and often are highly respected in their business
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.