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Employers Beware: Federal Government Continues its Laser Focus on Employment Tax Fraud
By on October 27, 2021
According to the IRS Criminal Investigation annual report, there were 2,596 criminal investigations initiated in 2020, of which 298 were employment tax cases. In January 2021, the Department of Justice Tax Division noted "employment tax enforcement is among the Tax Division's highest priorities." A recent example of the government's focus on employment tax fraud can be found in U.S. v. Christina Anglin (W.D. Okla. 2021). Ms. Anglin was the controller and CFO of a technology company in Oklahoma. As the controller, one of her responsibilities was withholding payroll taxes (Social Security and Medicare taxes and federal income taxes) and paying them to the IRS.
The Impact of Delinquent International Informational Returns on the IRS Statute of Limitations
By on October 7, 2021
Early this year the U.S. Tax Court released a decision in Kelly v. Commissioner, which, among other things, discusses how a delinquent international return impacts the IRS statute of limitations for assessment. It is a welcomed partial win for a taxpayer and contains a good discussion of reliance on a tax professional as the basis for reasonable cause.
