Publications Archives - Page 4 of 28

Payroll Tax Evasion Notice Suggests FinCEN’s New Focus

By Andrew Weiner and Jay R. Nanavati Law360 September 6, 2023 On Aug. 15, the Financial Crimes Enforcement Network within the U.S. Department of the Treasury issued Notice FIN-2023-NTC1 to advise U.S. financial institutions of the need to report payroll tax evasion and workers’ compensation

Diversity In The Tax Bar — Reflections On Lessons Learned And The Path Forward

By Stephen A. Josey, Sanessa S. Griffiths, Alyssa Pratt, and Lena Qiu Tax Notes Volume 180, September 4, 2023 Stephen Josey, Sanessa Griffiths, Alyssa Pratt, and Lena Qiu are tax practitioners who attended and reported on 9 panels conducted by the Tax System Working Group

IRS Doesn’t Have It Easy With Malta Pension Enforcement Efforts

By Caroline Ciraolo, Don Fort, and Ian Weinstock Bloomberg Tax August 28, 2023 High-net-worth US taxpayers, working with professional advisers, have transferred assets into personal retirement plans established in Malta to limit and potentially eliminate tax on distributions. These so-called Malta pension plans rely on

Diamonds in the Rough Notes: The Importance of Obtaining Informal Notes of Witness Statements

By Daniel Cady Davidson New York State Bar Association Journal August 16, 2023 For the trial attorney, familiarity with prosecution witnesses’ statements is fundamental to effective trial preparation. A recent federal health care fraud case in Texas (U.S. v. Swiencinski) underscores just how critical it

When Past Is Prologue: Why the Justice Department’s Revised Corporate Enforcement Policies May Create More Problems Than They Solve

By Sharon McCarthy and Christopher Ferguson American Bar Association Criminal Justice Section, The White Collar Crime Committee Newsletter Summer/Fall 2023 Edition We are all familiar with the aphorism that those who forget history are condemned to repeat it. The Department of Justice’s (“DOJ” or the

IRS Criminal Probe Spells Uncertainty For Malta Pension Plans

By Michael Sardar, Don Fort, and Caroline Ciraolo Law360 July 28, 2023 Malta pension plan arrangements under the U.S.-Malta income tax treaty have been a focus of the Internal Revenue Service and U.S. Department of the Treasury for more than two years. That focus intensified

An Inconvenient Truth About Remote Work

By Stephen A. Josey CPA Journal May/June 2023 The “convenience of the employer” rule for sourcing income to a particular state is anything but convenient for tri-state taxpayers. Most states that levy an income tax look to where an employee’s work is performed in determining

Revisions to Form 14457 Could Facilitate Crypto Disclosures

By Garrett L. Brodeur and Mia Bailey Tax Notes Federal July 10, 2023 The IRS considers voluntary compliance to be the “cornerstone of our tax system,” but the application form for the IRS’s voluntary disclosure practice (VDP), Form 14457, “Voluntary Disclosure Practice Preclearance Request and

IRS’s Efforts in Providing Cryptoasset Guidance are Clear

By Garrett L. Brodeur Tax Notes Federal July 3, 2023 In a recent Letter to the Editor, Garrett L. Brodeur noted that several recent informal guidance documents on the tax treatment of cryptoassets suggest that the IRS is striving to provide meaningful direction, even under

The State of the Tax Whistleblower Law

By Usman Mohammad and Ashley Morales ABA Tax Times June 2023 Internal Revenue Code section 7623(b) provides mandatory awards to whistleblowers who provide information to the IRS that results in the collection of additional tax, interest, penalties or fines from corporations, high net worth individuals,