Under 26 U.S.C. § 7216, it is a crime for a tax return preparer to knowingly or recklessly disclose any tax return information, or use that information other than in tax return preparation. There are also civil penalties under 26 U.S.C. § 6713 for wrongful
By: Caroline Rule The American Bar Association, Section of Litigation, Criminal Litigation Committee November 15, 2018 If you are an attorney who practices in the criminal tax area, be aware of 26 U.S.C. § 7216, which makes it a crime for a tax return preparer to
By Eric Smith The CPA Journal November 2018 Edition When an individual receives a settlement or litigation award payment, the likely first question is whether the payment is taxable. While CPAs may know that the answer will depend upon the claim underlying the lawsuit, several other
By Christopher M. Ferguson AICPA Tax Insider Newsletter October 25, 2018 The recent end of the OVDP is not the end of IRS enforcement of undisclosed offshore accounts. For most of the past decade, the IRS has maintained a safe harbor for taxpayers who want to
By: Bryan C. Skarlatos & Michael Sardar June – July 2018 Edition Journal of Tax Practice & Procedure Imagine a situation in which Congress passed a statute establishing civil penalties for certain conduct, including the maximum penalty that may be imposed for such conduct, and delegated enforcement of
By Wilda Lin The CPA Journal October 2018 Edition Reports of Foreign Financial and Bank Accounts (FBAR) have gained prominence since the Department of Justice began investigating the accounts of Swiss banks, starting with UBS almost a decade ago. Who must file FBARs? Many people
