Tax Controversy Sentinel Blog

https://taxcontroversy.foxrothschild.com/

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

  • New IRS CI Chief Describes Enforcement Priorities, Launch of Special Investigation Units Matthew D. Lee was featured in the Wolters Kluwer article, “New IRS CI Chief Describes Enforcement Priorities, Launch of Special Investigation Units.”  Please click here to view the article. For more up-to-date coverage from Tax Controversy Sentinel, please subscribe by clicking here.... More
  • FATCA Update: FFI Agreement Renewal Deadline Extended to October 24, 2017 The Internal Revenue Service has extended the deadline for foreign financial institutions (FFIs) to renew their FFI Agreements to October 24, 2017.  We previously wrote about the IRS’ publication in late 2016 of an updated “FFI Agreement” to be entered into by foreign financial institutions that wish to remain compliant with the Foreign Account Tax Compliance Act (FATCA). All foreign financial institutions that had in effect an FFI Agreement that expired on December 31, 2016, and that wished to retain... More
  • Connecticut Announces Arrest of Restaurant Owner for Using “Zapper” Tax Suppression Software Connecticut’s Department of Revenue Services (DRS) has arrested and charged a New Haven restauranteur with various offenses for using sales tax suppression software. According to a press release announcing the charges, this is the first time the State of Connecticut has charged an individual for using “zapper” software, which it describes as “a type of commercial ‘phantom-ware’ used to create fraudulent point-of-sale records that deliberately understate taxes actually collected.” Zapper programs are used to delete some or all of a... More
  • No Rest for the Weary: Offshore Tax Evasion Crackdown Continues with Flurry of Mid-Summer Activity Dashing any thought that they were taking a hiatus from investigating and prosecuting taxpayers with secret offshore bank accounts and the bankers that helped them, the Justice Department and Internal Revenue Service have unleashed an avalanche of new enforcement activity in the final days of July. Since 2008, the government has criminally charged more than 160 U.S. taxpayers who maintained secret offshore bank accounts. During that same time period, the government has charged more than 50 “enablers” – foreign bankers,... More
  • IRS Appeals Will Now Offer “Virtual” Taxpayer Conferences The Internal Revenue Service’s Office of Appeals has announced that it will soon unveil a pilot project affording taxpayers and their representatives the opportunity to have a “virtual” face-to-face option for taxpayer conferences. Currently, taxpayers requesting an Appeals conference have the opportunity to conduct such conference by telephone, in person (referred to as a “face-to-face” conference), or virtually through videoconference technology which is available at only a limited number of IRS offices. Each year, the Office of Appeals hears appeals... More
  • DOJ’s Prosecution of Health Care Exec Illustrates Unique Intersection of Securities & Employment Tax Fraud Schemes In a recent criminal prosecution of a medical doctor/entrepreneur for defrauding his company’s shareholders, the government employed a novel theory of securities fraud premised, in part, upon the defendant’s failure to pay federal employment taxes withheld from his employees’ wages. The government alleged that the defendant, Sreedhar Potarazu, an ophthalmic surgeon licensed in Maryland and Virginia, made repeated false statements to shareholders about the financial condition of VitalSpring Technologies Inc., a company he founded, including concealing the fact that the... More
  • FATCA Update: IRS Publishes FAQs As July 31 FFI Agreement Renewal Deadline Looms We have previously written about the Internal Revenue Service’s publication in late 2016 of an updated “FFI Agreement” to be entered into by foreign financial institutions that wish to remain compliant with the Foreign Account Tax Compliance Act (FATCA). All foreign financial institutions that had in effect an FFI Agreement that expired on December 31, 2016, and that wish to retain their GIIN and thereby remain FATCA-compliant, must do so by July 31, 2017. Those financial institutions that are required... More
  • FinCEN Issues Marijuana Banking Update Over at the In The Weeds blog (which explores developments in cannabis law and business), Melissa T. Sanders writes about the recent publication by the Treasury Department’s Financial Crimes Enforcement Network of its “Marijuana Banking Update.”  In this publication, FinCEN summarizes the number of depository institutions providing banking services to marijuana-related businesses in the United States as reported by the filing of “suspicious activity reports” (SARs).  Marijuana-related businesses present myriad anti-money laundering compliance challenges, as well as complex federal tax issues as... More
  • IRS Warns Consumers of New Phone Scam Just as Private Collectors Get to Work Earlier this year we wrote that the Internal Revenue Service is moving forward with its controversial “Private Debt Collection” program amid a sharp uptick in instances of fraud by scammers posing as legitimate IRS debt collectors. The new private tax collector program, authorized under a federal law enacted by Congress in December 2015, enables designated private contractors to collect, on behalf of the IRS, unpaid tax debts. Usually, these are unpaid individual tax obligations that are not currently being worked... More
  • FATCA Update: IRS Releases Updated FATCA Online Registration User Guide The Internal Revenue Service has released an updated version of its “FATCA Online Registration User Guide.” The updates primarily address the newly-released FFI agreement renewal function, which is now available on the IRS FATCA portal and is to be used by foreign financial institutions to renew their FFI Agreements. The user guide provides the following description of the updates reflected in the new version: What’s New We have updated the December 2016 version of the Foreign Account Tax Compliance Act (FATCA) Online... More