What should you do if you discover that you made mistakes on last year’s federal returns when doing your taxes in 2025? Or, what if you already knew that you made mistakes, and you want to address them so that you are not at risk in the event of an […]
Category: Tax Controversy
Understanding FinCEN’s Beneficial Ownership Reporting Requirements (and the Risks of Non-Compliance)
In the summer of 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) launched a communications campaign “to educate the small business community about new beneficial ownership reporting requirements.” For existing companies, the obligation to file beneficial ownership reports with FinCEN took effect on January 1, 2024. For companies […]
The Internal Revenue Service (IRS) confirmed this month that it will be classifying syndicated conservation easements as abusive tax transactions going forward. While syndicated conservation easements have long been a red flag for the IRS, this new development increases the risks for taxpayers who rely on syndicated conservation easements to […]
For high-income and high-net-worth U.S. taxpayers who are at risk of facing criminal prosecution due to willful tax law violations, making a voluntary disclosure to IRS Criminal Investigation (IRS CI) can facilitate a favorable resolution that avoids formal charges. But, making a voluntary disclosure presents its own risks—and it isn’t […]
The IRS’s Voluntary Disclosure Practice (VDP) and its Streamlined Filing Compliance Procedures both provide ways for high-income and high-net-worth taxpayers to proactively resolve issues related to the disclosure (or non-disclosure) of their offshore assets. But, the VPD and Streamlined Filing Compliance Procedures are very different—each being subject to its own […]
The Voluntary Disclosure Practice (VDP) provides an avenue for high-income and high-net-worth taxpayers to resolve significant federal tax controversies without facing criminal prosecution. Administered by IRS Criminal Investigation (IRS CI), the VDP is a long-standing program that allows eligible taxpayers to mitigate their exposure and settle with the IRS—provided that […]
The Internal Revenue Code requires U.S. taxpayers to disclose certain transactions resulting in significant losses. The Internal Revenue Service (IRS) classifies these as “reportable transactions” due to their potential to serve as abusive tax shelters; and, as the IRS makes clear, “[e]ach taxpayer that has participated in a reportable transaction […]
While the national public health emergency related to the COVID-19 pandemic may have ended in 2023, combating COVID-related fraud remains a top federal law enforcement priority in 2024. The Internal Revenue Service (IRS) is one of several agencies involved in the government’s ongoing response, and IRS Criminal Investigation (IRS CI) […]
The Internal Revenue Service (IRS) is continuing to prioritize cryptocurrency-related compliance in 2024. As we previously discussed, the IRS identified digital asset compliance as one of its three “priority areas” for enforcement in 2024, and it recently issued a News Release reminding U.S. taxpayers of the obligation to report cryptocurrency […]
On December 6, 2023, the Internal Revenue Service (IRS) announced that it was sending an “initial round” of 20,000 letters to taxpayers informing them that their Employee Retention Credit (ERC) claims had been denied. According to the IRS’ press release, the letters reflect the agency’s “increased scrutiny of ERC claims in […]