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Federal Agent Steals Virtual Currency and Receives Real World Prison Sentence
By on October 28, 2015
On October 19, 2015, a former Drug Enforcement Agent, Carl Force, was sentenced to 78 months in prison for stealing bitcoin related to the federal criminal investigation of Silk Road.
New DOJ Policy Regarding Individual Accountability for Corporate Wrong Doing
By on October 27, 2015
On September 9th the Department of Justice (DOJ) issued new guidance to its prosecutors aimed at encouraging more white collar criminal and civil cases against corporate executives. The new rules take effect immediately, but they are not likely to apply to investigations that are far along.
The OECD's BEPS Initiative and International Tax Reform
By on October 26, 2015
The Organization for Economic Cooperation and Development's (OECD) Base Erosion and Profit Shifting (BEPS) initiative is headed for the home stretch. Whether it will cross the finish line, however, remains to be seen.
By on October 21, 2015
On Oct. 16, 2015, the IRS announced that its offshore compliance programs have generated $8 Billion in IR-2015-116. More than 54,000 taxpayers have participated in IRS offshore remediation disclosure programs since 2009. The IRS warned taxpayers with non-compliant offshore accounts to "strongly consider existing paths established to come into full compliance with their federal tax obligations."
Using a Qualified Amended Return to Avoid the Accuracy-Related Penalty
By on October 12, 2015
When a taxpayer or tax professional discovers an error on a previously filed tax return, the taxpayer usually asks whether and how the error should be corrected. While there is nothing in the Internal Revenue Code or Regulations requiring a taxpayer to amend a tax return, CPAs and other tax professionals have a duty under Circular 230 and ethical rules to advise a taxpayer that an amended tax return should be filed and that failure to do so could result in imposition of penalties. If a taxpayer chooses not to file an amended return, he or she could be subject to an accuracy-related penalty pursuant to IRC Section 6662.
Are Tax Returns Given to an IRS Agent Considered Filed?
By on October 5, 2015
In the typical IRS delinquent tax return examination, the IRS agent will ask that the original delinquent returns be delivered to him or her for filing. Because providing tax returns and other information, such as refund claims, is not considered filing, I will usually file the returns with the IRS Service Center, and provide a copy to the agent with proof of filing. By doing so, I know that a tax return or refund claim has been properly and promptly.