Federal Tax Crimes

Jack Townsend offers this blog on Federal Tax Crimes principally for tax professionals and tax students. It is not directed to lay readers -- such as persons who are potentially subject to U.S. civil and criminal tax or related consequences. LAY READERS SHOULD READ THE PAGE IN THE RIGHT HAND COLUMN TITLE "INTENDED AUDIENCE FOR BLOG; CAUTIONARY NOTE TO LAY READERS." Thank you.

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Jack Townsend: Houston, TX, United States

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Federal Tax Crimes

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Sixth Circuit Approves NonDetailed Allegations of Ownership in Making Claim for Seized Property Sought to be Forfeited (9/24/17)

Second Circuit Orders Abatement of Criminal Conviction on Appeal but (i) Denies Abatement of Tax Conviction Not Appealed and (ii) Affirms $48 Million Bail Bond Revocation (9/24/17)

Big Win for Taxpayer/Filer in FBAR Willful Penalty Case (9/21/17; 9/23/17)

DOJ Tax Targeting Swiss Life Insurance Companies Offering Insurance Wrappers to Help U.S. Taxpayers Evade Tax (9/16/17)

Order on Motion In Limine and Trial Briefs in Case Involving FBAR Willful Penalty (9/11/17)

KPMG Report Indicates 60 or 70 Swiss Private Banks are in Serious Difficulty (9/8/17)

Eighth Circuit Rejects Argument of Prosecutor Abuse in Closing Argument (9/8/17)

Consideration of Sentencing Disparities in Sentencing (9/3/17; 9/8/17)

Taxpayer Held Liable for Civil Fraud Penalty after Plea to Tax Evasion for One of the Years (9/2/17; 9/10/17)

Sixth Circuit Holds Government did not Prove Fugitive Disentitlement for Civil Forfeiture (9/1/17)

Deliberate Ignorance Instruction Previously Rejected Allowed Based on Defense Closing Argument (8/31/17)

HMRC Enlists Financial and Other Professionals to Warn UK Citizen Clients About Offshore Accounts (8/23/17)

Agostino & Associates Article on Executor Risks for Decedent's Foreign Accounts (8/21/17)

Sixth Circuit Rejects Frontal Assault on FATCA, IGAs and FBAR Requirements (8/20/17)

Swiss Asset Manager and DOJ Enter Nonprosecution Agreement (8/15/17 8/18/17)

Indictment of Taxpayers for Evasion of Payment and Structuring Cash Withdrawals (8/14/17)

Court Sustains $10,000 Per Year § 6038(b) Penalty for Form 5471 Noncompliance for Taxpayer Who Withdrew from 2009 OVDP (8/9/17)

USSC Practitioners Advisory Group Recommendations on Sentencing Commission Priorities (8/8/17)