Robert M. Russell was quoted in a recent Tax Notes article entitled “Senate International Plan Not Without Taxpayer ‘Silver Linings,’” published on April 15, 2021. Russell comments on various proposals within the Senate Democrats’ international tax framework, released on April 5, 2021. The article notes:
In Crandall v. Commissioner (available here), in a win for taxpayers who have gone through the IRS’s offshore voluntary disclosure program (OVDP), the United States Tax Court held that the IRS was bound by the terms of a closing agreement and could not assert a
The Joint Chiefs of Global Tax Enforcement (J5)— tax authorities of Australia, Canada, Holland, the UK, and the US—recently convened investigators, cryptocurrency experts, and data scientists in a virtual event, “The Challenge,” where the J5 honed in on developing leads and jumpstarting investigations into criminals’
The Internal Revenue Service (IRS) and the U.S. Department of Justice (DOJ) recently showed their hands in their ongoing fight against tax noncompliance relating to cryptocurrency. The IRS is authorized by statute to issue John Doe administrative tax summonses to obtain information from third-parties regarding
Robert M. Russell was quoted in a recent Law360 article entitled “Speed of TCJA Passage May Handicap Treasury in Disputes,” published on March 31, 2021. Russell observes that the swift passage of the TCJA has led to a host of regulatory disputes with the Treasury
In a recent New York Times article entitled “An Accidental Disclosure Exposes a $1 Billion Tax Fight With Bristol Myers,” Bryan C. Skarlatos weighed in on the potential outcome of a tax controversy between the Internal Revenue Service and Bristol Myers Squibb, an American drugmaker.
Caroline D. Ciraolo was quoted in a recent Tax Notes article entitled “Practitioners Fear Pandemic’s Impact on Voluntary Disclosures,” published on March 25, 2021. The article focuses on discussion from a recent panel hosted by the District of Columbia Bar Taxation Community entitled “IRS Undeterred:
The Ninth Circuit Court of Appeals recently ruled in favor of a taxpayer subject to a non-willful civil penalty for failure to timely file an accurate Foreign Bank Account Report (FBAR), agreeing with a position advanced in a friend of the court brief written by
By Christopher M. Ferguson and Hannah Ambinder On March 3, 2021, the Financial Action Task Force (FATF) and Egmont Group of Financial Intelligence Units (Egmont Group) released Trade-Based Money Laundering: Risk Indicators, a publication outlining anti-money laundering risk factors. The FATF Report’s purpose is to
