Showing posts from December, 2014

Offshore Enforcement to Remain Top Priority in 2015

Practitioners and students of tax crimes know that most of the commonly charged tax crimes have an element of willfulness which the Supreme Court interpreted in Cheek to mean a voluntary intentional violation of a known legal duty.

The reality however, is that some tax crimes do not have an explicit requirement of willfulness but have an equivalent element that substantially overlaps willfulness. E.g., Section 7212(a)'s requirement that the defendant act corruptly and even the defraud conspiracy in 18 USC 371. See John A. Townsend, Tax Obstruction Crimes: Is Making the IRS's Job Harder Enough,  - Hous. Bus. & Tax. L.J. 255, 277-314 (2009), here.

As tax professionals, it is critical that we keep as close to the IRS as possible to understand how they view and interpret certain situations.  In this effort, here's an extract copied directly from the very popular Federal Tax Crimes blog -

A recent Tax Notes Today article reports on the Criminal Fraud and Tax Controversy Con…

What you need to know about the Singapore-US FATCA agreement