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
By Usman Mohammad The CPA Journal February 2020 Edition Foreign asset reporting—including the reporting of foreign retirement plans—is a high priority for the IRS, which in 2019 listed the “failure to report offshore funds” as one of its “Dirty Dozen Tax Scams,” and has done so
By Michael Sardar The CPA Journal January 2020 Edition Cryptocurrency is here to stay. As of November 17, 2019, the top five cryptocurrencies by market capitalization had a combined value of approximately $196 billion, and consumers can now use cryptocurrency in place of legal tender at
By Megan L. Brackney Procedurally Taxing January 8, 2020 The Gifts That Keep on Giving Two young people moved to the U.S. as students. They met in graduate school and married. After graduation, they were offered jobs and were sponsored by their employers so that they
By Megan L. Brackney Procedurally Taxing January 7, 2020 Reasonable Cause For all of the foreign information return penalties, reasonable cause is a defense. See I.R.C. §§ 6038, 6038A(d)(3), 6038D(g), 6039F(c)(2), 6677(d); Treas. Reg. § 1.6038-2(k)(3)(ii). The IRS applies the same standards for reasonable cause for failure to file income tax returns under I.R.C. §
By Megan L. Brackney Procedurally Taxing January 6, 2020 The IRS has been assessing more and more foreign information return penalties on taxpayers. It is difficult to find statistics on this point, as the IRS’s reports on tax penalties lump all “nonreturn” penalties into one category, which
By Eric Smith The CPA Journal December 2019 Edition Thanks to legalized sports gambling, U.S. casinos generated a record amount of gaming revenue in 2018. As might be expected, it is becoming increasingly common for individuals to have questions regarding the taxation of gambling income and
By Caroline Rule ABA Section of Litigation, Criminal Litigation Committee December 5, 2019 Always request a DOJ Tax Division conference as soon as it appears that your client may face federal criminal tax charges. Suppose that you have a client who can afford for you to
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
By Caroline Rule The CPA Journal November 2019 Edition Under Internal Revenue Code (IRC) section 7216 and its concomitant regulations, a tax preparer must obtain the consent of a taxpayer before disclosing or using the taxpayer’s tax return information when that consent is required. Section 7216
