By Megan L. Brackney Tax Notes Federal September 28, 2020 In a Sept. 28, 2020 Tax Notes article entitled, “Focus on High-Net-Worth Nonfilers,” Megan Brackney examines what taxpayers who fail to file returns can expect from the IRS, and she offers strategies to avoid some of the harsher potential consequences of
By Megan L. Brackney The CPA Journal June 2020 Edition The Internal Revenue Code and the Bank Secrecy Act (BSA) require that persons engaged in a trade or business file Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business, any time the business receives more than $10,000
By Megan L. Brackney Tax Notes Federal April 27, 2020 Given that combating tax fraud is a top agency priority, it is a good time to review the law and procedures related to tax fraud. In this article, Megan Brackney discusses the ways the IRS identifies and addresses fraud, the consequences
By Caroline D. Ciraolo Journal of Tax Practice and Procedure Spring 2020 Edition At the 35th Annual UCLA Extension Tax Controversy Institute, Caroline D. Ciraolo and her fellow panelists addressed international tax compliance and enforcement, including what’s old, what’s new and what we can expect going forward. “We cannot continue to operate
Caroline Rule’s article, “United States v. Greenfield: A Triumph of the Fifth Amendment’s Act of Production Privilege; or Confirmation that the Privilege Can Be Entirely Abrogated by Any Act of Congress, or Even by a Treasury Regulation?” published in The Tax Lawyer, Winter 2018 (71:2), has been selected for inclusion
By Caroline Rule and Bob Fink Law 360 Twenty years ago, we put forward what was then a novel concept — that the IRS and the U.S. Department of Justice were misusing the tax code to make their jobs easier. Our topic was the misuse of a statute that, we contended, was reserved for prosecuting the deliberate
By Megan L. Brackney Tax Notes In this article, Brackney discusses the John Doe summons procedures and the decision partially enforcing a John Doe summons in Coinbase. She also identifies some practical considerations for taxpayers whose information may be turned over to the IRS in accordance with the summons. Full Article
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
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 travel to Washington, D.C., and
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
