Tax Controversy Sentinel Blog

Matt serves as the editor for the firm's Tax Controversy Sentinel blog, which reports on the latest developments in all aspects of tax controversy matters. These include criminal tax investigations and prosecutions, civil tax matters before the Internal Revenue Service including audits, appeals, and collection matters, as well as tax litigation. The blog also covers international tax compliance issues, including foreign bank account reporting (FBAR), the Foreign Account Tax Compliance Act (FATCA), and the IRS’s voluntary disclosure programs for both domestic and offshore issues.  Finally, Tax Controversy Sentinel addresses compliance issues arising under the Bank Secrecy Act, the USA Patriot Act, FATCA, the anti-money laundering laws and regulations, and economic sanctions regimes.

Recent Blog Posts

  • FinCEN Provides FBAR Relief to Victims of the California Wildfires The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced today that California wildfire victims in affected areas of California have until January 31, 2018, to file their Report of Foreign Bank and Financial Accounts (FBAR) report for the 2016 calendar year. The FBAR for calendar year 2016 would otherwise have been due October 15, 2017. FinCEN is now offering this expanded relief to any area designated by the Federal Emergency Management Agency (FEMA) as qualifying for individual assistance or public assistance.... More
  • Treasury Hints That Regulatory Review May Target FATCA Regulations In a report to the President recommending actions to eliminate or mitigate burdens imposed on taxpayers by eight specific tax regulations, the Treasury Department indicated that it is considering possible reforms of regulations issued pursuant to the Foreign Account Tax Compliance Act (FATCA). Enacted in 2010 and fully effective as of July 1, 2014, FATCA is a wide-reaching anti-tax evasion law that requires foreign banks and financial institutions to annually disclose to the Internal Revenue Service the identities and other... More
  • IRS Delays Start Date for Program to Revoke Passports for Tax Delinquents The Internal Revenue Service has once again delayed the start date for implementation of a new law authorizing the State Department to revoke the passports of taxpayers with sizeable tax debts.  According to an IRS web site page entitled “Revocation or Denial of Passport in Case of Certain Unpaid Taxes” (updated as of September 6, 2017), the IRS has not yet started certifying tax debt to the State Department, and such certifications will not begin until January 2018.  As we noted in prior posts (here, here, and here), the... More
  • FinCEN Provides Updated FBAR-Filing Relief to Victims of Hurricanes Harvey, Irma, and Maria The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) today updated two previous notices regarding FBAR-filing relief to victims of the recent hurricanes.  Extension filers have until January 31, 2018 to file their FBAR forms for calendar year 2016, which would otherwise be due October 15, 2017. First, FinCEN updated the notice issued September 7, 2017, which provides FBAR-filing relief to victims of Hurricane Harvey, to expand the relief to include victims of Hurricane Harvey in additional areas that the Federal Emergency Management Agency (FEMA)... More
  • SEC Continues Its Focus on EB-5 Immigrant Visa Fraud Earlier this year we wrote about the Justice Department’s continuing efforts to combat fraud in the EB-5 immigrant visa program, with the filing of several federal lawsuits seeking the forfeiture of nine real properties across Southern California that were allegedly purchased with proceeds generated by a fraudulent scheme that collected more than $50 million from foreign investors seeking “green cards” through the EB-5 program. Those suits alleged that much of the money collected from investors, who were primarily Chinese, either... More
  • Fox Rothschild Wins Landmark Victory for Taxpayer in FBAR Case Fox Rothschild LLP attorneys Patrick J. Egan and Beth L. Weisser won a significant victory in a trial against the IRS when a federal judge rejected the government’s demand for more than $1 million in penalties and also awarded a refund of a payment previously made by Fox client Arthur Bedrosian. The verdict handed down by U.S. District Judge Michael M. Baylson is the only case to date in which the IRS has not prevailed in its attempt to collect a... More
  • FinCEN Warns U.S. Financial Institutions of Venezuelan Money Laundering Threat The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has issued an advisory to alert financial institutions of widespread public corruption in Venezuela and the methods Venezuelan senior political figures and their associates may use to move and hide proceeds of their corruption through the U.S. financial system. The advisory also describes a number of financial red flags to assist financial institutions in identifying and reporting suspicious activity that may be indicative of corruption. “In recent years, financial institutions have reported to FinCEN... More
  • BNA Reports That Tax-Zapping Software Costs States $21 Billion in Taxes Annually BNA’s Michael J. Bologna and Paul Shukovsky have written a comprehensive article about a pervasive problem facing state tax auditors:  the use by restaurants and other cash-intensive businesses of electronic revenue suppression software, commonly referred to as “Zappers.”  We have previously blogged about efforts by state and federal tax authorities to crack down on the use of “Zapper” software here (reporting on the Connecticut Department of Revenue’s arrest of a New Haven restauranteur) and here (predicting a federal crackdown on tax... More
  • IRS Urges Foreign Financial Institutions to Renew Their FATCA Registrations The Internal Revenue Service has issued a reminder to foreign financial institutions to renew their Foreign Financial Institution (FFI) agreement if required. These FFIs have until October 24, 2017 to complete their renewal. Those that fail to renew their agreements could be removed from the November FFI list and be subject to a 30 percent tax on certain U.S. source payments. “We’ve worked with foreign financial institutions to implement FATCA registration and information reporting,” said Large Business & International Commissioner Doug O’Donnell.... More
  • Bill Introduced in Congress to Exempt Small Bitcoin Transactions From Income Tax Two members of Congress have introduced a bill that would exempt from income tax transactions under $600 conducted using Bitcoin or other digital currencies. Currently, the Internal Revenue Service treats digital currencies like Bitcoin as property, meaning that on every transaction using Bitcoin, the taxpayer must recognize either a gain or loss for tax purposes depending on his or her basis in the digital currency and report such gain or loss on an income tax return. The IRS does not... More