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

  • Matthew D. Lee Authors 2020 Update to FATCA Answer Book Fox Rothschild LLP Partner Matthew D. Lee authored an updated version of the Foreign Account Tax Compliance Act Answer Book, which summarizes the latest developments with respect to the FATCA regulatory framework, including new regulations issued in early 2020 and the current status of negotiations of intergovernmental agreements to enforce FATCA around the globe. The update includes discussion of enforcement efforts by the Internal Revenue Service, such as a new compliance campaign aimed at FATCA reporting by foreign financial institutions, as well... More
  • Early Cases Demonstrate the Justice Department’s Commitment to Aggressively Prosecute PPP Loan Fraud By Matthew D. Lee and Marissa Koblitz Kingman Shortly after the Small Business Administration began accepting applications for Paycheck Protection Program (PPP) loans, two Rhode Island businessmen quickly applied for a combined $543,881 from the program. A few days later, the Justice Department announced that both were criminally charged with conspiracy to make false statements to influence the SBA and conspiracy to commit bank fraud, becoming the first individuals to face criminal charges related to the program, which was created by... More
  • Resources Regarding “People First Initiative” Available on IRS Website On March 25, 2020, following the onset of the COVID-19 pandemic, the IRS unveiled its People First Initiative to provide wide-ranging compliance relief to taxpayers experiencing hardships relating to the health crisis. This relief includes issues ranging from postponing certain payments related to Installment Agreements and Offers-in-Compromise to collection and limiting certain enforcement actions. The IRS has created a resource page on its website ( providing significant details regarding the People First Initiative, including Frequently Asked Questions and Answers about... More
  • U.S. Tax Court to Begin Accepting Hand Deliveries on July 10 Following up our post earlier today that the Tax Court will resume receiving mail on July 10, 2020, the Tax Court has issued another announcement regarding its operations.  Also beginning on July 10, the Clerk’s Office will accept hand-delivered documents between the hours of 8:00 AM and 4:30 PM, Monday through Friday. Please check out Fox Rothschild’s COVID-19 resource page, which is available here. For more up-to-date coverage from Tax Controversy and Financial Crimes Report, please subscribe by clicking here.... More
  • Tax Court Announces Resumption of Mail Delivery Due to the COVID-19 pandemic, operations of the United States Tax Court have been severely impacted.  The Tax Court’s building in Washington, D.C. has been closed since March 19, 2020, all trial sessions have been cancelled through the end of June, and all Tax Court employees, including judges, have been working remotely. Due to the closure of the Tax Court building, no mail has been delivered to the building. All mail was to be held until the Court reopened, although many... More
  • Protecting Your Organization Against Paycheck Protection Program Qui Tam Actions Our colleague Jana Volante Walshak has published an article addressing the steps that businesses can take now to protect themselves against qui tam actions related to the CARES Act Paycheck Protection Program. Many organizations may have thought the “hard part” was over when they received loans under the Paycheck Protection Program. In reality, the hard part is only beginning for loan recipients as they attempt to comply with the program’s constantly changing regulatory scheme. The uncertain nature of the rules and regulations... More
  • Fox Rothschild’s Securities Industry Group Members Oksana Wright and Charles DeMonaco Publish Article on Corporate Compliance Measures During the COVID-19 Crisis Our colleagues Oksana Wright and Charles DeMonaco have published an article in Corporate Compliance Insights discussing management and corporate compliance measures for companies to prioritize during the uncertainty posed by COVID-19 pandemic.  You can read their article here. Please check out Fox Rothschild’s coronavirus resource page, which is available here. For more up-to-date coverage from Tax Controversy and Financial Crimes Report, please subscribe by clicking here.... More
  • Internal Revenue Service’s LB&I Division Announces Compliance Campaign Focused on TCJA The Internal Revenue Service’s Large Business & International Division has announced another compliance campaign, its 64th such campaign since the first set of campaigns was unveiled in 2017. This latest campaign will focus on the Tax Cuts and Job Act legislation enacted in late 2017. These compliance 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... More
  • IRS Grants Financial Institutions Temporary Reprieve from FATCA Obligations Due to COVID-19 In response to the COVID-19 pandemic, the IRS has granted foreign financial institutions a number of extensions on Foreign Account Tax Compliance Act reporting obligations due in 2020. First, the IRS granted any foreign financial institution with a FATCA compliance certification deadline of July 1, 2020, an automatic extension to December 15, 2020.  See FAQ 21.  No extension request must be filed in order to obtain this relief. Second, the IRS granted an extension of time for any Reporting Model 2 FFI... More
  • IRS Provides Critical Guidance on How to Obtain Tax Levy and Lien Releases Due to COVID-19 Hardships The Internal Revenue Service has published two Frequently Asked Questions about how taxpayers can seek release of tax levies and federal tax liens due to hardship circumstances caused by the COVID-19 pandemic.  The FAQs can be found at the bottom of the IRS web page entitled “IRS Operations During COVID-19: Mission-critical functions continue,” which is available here. According to the FAQs, tax levies will not be automatically released because of the COVID-19 pandemic, but the IRS will consider taxpayer requests to... More