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, a website where illegal goods were sold...
Category: Blog
New DOJ Policy Regarding Individual Accountability for Corporate Wrong Doing
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,...
The OECD’s BEPS Initiative and International Tax Reform
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....
IRS Announces it Has Raised $8 Billion Through its Offshore Remediation Programs While Conducting Thousands of Civil Offshore Exams and Numerous Criminal Offshore Investigations
BACKGROUND 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...
Using a Qualified Amended Return to Avoid the Accuracy-Related Penalty
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...