Taxation & Wealth Planning

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Tax Controversy & Financial Crimes Report

The increasingly complex area of tax law in the U.S. can cause a variety of legal setbacks for any business. The more notable the tax controversy, the more roadblocks that can be created between a company and its success. Our Tax Controversy & Financial Crimes Report blog addresses the latest developments in all aspects of tax controversy matters and incorporates coverage of efforts to combat financial crimes, particularly money laundering.

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Recent Blog Posts

  • Fox Rothschild Attorneys to Present at PACDL’s Annual White Collar Conference Fox Rothschild attorneys Ryan T. Becker and Matthew D. Lee will be speaking next week at the annual White Collar Practice conference sponsored by the Pennsylvania Association of Criminal Defense Lawyers.  The conference will take place on November 21-22, 2019, in Philadelphia. Ryan will be moderating a panel entitled “Internal Investigations:  Protecting Your Client While Placating the Government.” Matt will be speaking on a panel entitled “What You Really Need to Know if You Are Taking on a Criminal Tax Case.” Details about the... More
  • IRS Steps Up the Pressure on Abusive Syndicated Conservation Easements The Internal Revenue Service announced today a significant increase in enforcement actions for syndicated conservation easement transactions, a priority compliance area.  According to the announcement, coordinated audits are being conducted throughout various examination divisions of the IRS.  At the same time, the IRS Criminal Investigation division has criminal investigations underway in this area. These audits and investigations cover billions of dollars of potentially inflated deductions as well as hundreds of partnerships and thousands of investors. Syndicated conservation easements are included on the... More
  • Matthew D. Lee Updates Foreign Account Tax Compliance Act Answer Book for 2019 Fox Rothschild LLP Partner Matthew D. Lee authored an updated version of the Foreign Account Tax Compliance Act Answer Book, which was originally published by Practising Law Institute in 2015. This new edition addresses recent changes to FATCA regulations relating to compliance and verification procedures for a variety of entities, including sponsoring entities of foreign financial institutions; non-financial foreign entities; trustees of trustee-documented trusts; registered deemed-compliant FFIs; and financial institutions that implement consolidated compliance programs. The update examines revisions to the responsible officer... More
  • Matthew D. Lee Updates Foreign Account Tax Compliance Act Answer Book for 2019 Originally published by Practising Law Institute in 2015, this new edition addresses recent changes to FATCA regulations relating to compliance and verification procedures for a variety of entities, including sponsoring entities of foreign financial institutions; non-financial foreign entities; trustees of trustee-documented trusts; registered deemed-compliant FFIs; and financial institutions that implement consolidated compliance programs. The update examines revisions to the responsible officer compliance certification process and the FATCA registration and renewal process. It also describes recent offshore tax evasion criminal and civil... More
  • FinCEN Unveils New Global Investigations Division to Target Foreign Money Laundering Threats The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced today that it has launched a new Global Investigations Division (GID), which will be responsible for implementing targeted investigation strategies to combat illicit finance threats and related crimes, both domestically and internationally. Matthew Stiglitz, a former Principal Deputy Chief in the Department of Justice’s Criminal Division, will lead GID. GID will build upon FinCEN’s existing authorities under the Bank Secrecy Act, including Section 311 of the USA PATRIOT Act, to investigate and... More
  • IRS Ramping Up Cryptocurrency Enforcement Efforts With “Educational” Letters The Internal Revenue Service announced today that it has begun mailing what it calls “educational letters” to taxpayers with cryptocurrency transactions who potentially failed to report income and pay the resulting tax from such transactions, or did not report their transactions properly. The IRS started sending these letters to taxpayers last week. By the end of August, more than 10,000 taxpayers will receive these letters. The IRS said it obtained the names of these taxpayers through “various ongoing IRS compliance... More
  • 59 and Counting: IRS LB&I Announces Six More Compliance Campaigns Earlier this week, the Internal Revenue Service’s Large Business & International Division announced six more compliance campaigns, bringing the total number of campaigns announced to date to a whopping 59. These campaigns reflect LB&I’s movement toward issue-based examinations and a compliance process in which LB&I decides which tax issues that present risk require a response in the form of one or multiple treatment streams to achieve compliance objectives. This approach is intended to make the best use of the IRS’s... More
  • New Jersey, New York, and Connecticut File Lawsuit Challenging New IRS SALT Cap Rule Earlier this week, the Attorneys General of New Jersey, New York, and Connecticut sued the Treasury Department and the Internal Revenue Service challenging a new IRS rule that would preclude individuals in those states from claiming deductions for charitable contributions to local governments. This lawsuit is the latest chapter in the battle over the “SALT cap,” enacted as part of the 2017 tax reform legislation which imposes a $10,000 annual limitation on the deduction for state and local taxes. Enacted in... More
  • FinCEN Unveils New Efforts to Combat Widespread Business Email Compromise Fraud Scams As Losses Reach $300 Million Per Month The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has announced new efforts to crack down on Business Email Compromise (BEC) schemes and those who profit from such scams.  BEC fraud schemes generally involve attempts to compromise the email accounts of victims to send fraudulent payment instructions to financial institutions or business associates in order to misappropriate funds or to assist in financial fraud.  Often, the unsuspecting victim is conned into thinking a legitimate email from a trusted person or entity is directing... More
  • DOJ Brings First-Ever Criminal Prosecution of Executives for Failing to Report Dangerous Product Defects By Kristina Burland and Matthew D. Lee A precedent-setting criminal prosecution of two California executives under the Consumer Product Safety Act is sending a strong warning to corporate boardrooms that the reporting requirements of the CPSA must be taken seriously and that a company’s compliance program must be thoughtfully designed to ensure that reports are submitted promptly. In an indictment handed up in March, a federal grand jury charged that Simon Chu and Charley Loh – executives of two California corporations... More