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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Court Enters Stipulated Order to Prevent Alienation of Swiss Account Holdings (12/27/21; 12/30/21)

FinCEN Adopts Immediately Effective Final Rule Omitting the Regulations Statement of the 2004 Willful Penalty Prior to the 2004 Statutory Amendment (12/26/21)

District Court for ED VA Dismisses Reverse False Claims Act Proceeding Against Credit Suisse (12/22/21)

Fifth Circuit Affirms Defendant's Waiver of Counsel Conflict of Interest and Punts on Ineffective Assistance of Counsel Claim on Direct Appeal (12/10/21)

Fifth Circuit Applies FBAR NonWillful Penalty Per Account and Not Per Form (11/30/21)

Civil Liability for Conduct that is Acquitted in Criminal Case (11/20/21)

District Court holds (1) FBAR Penalty Statute of Limitations is Waivable and (2) FBAR Nonwillful Penalty is Per Account (11/8/21)

District Court Upholds Repatriation Order for FBAR Willful Penalty While Liability on Appeal (11/4/21; 11/5/21))

District Court Holds that Custodial FBI Investigation on Arrest for Nontax Crime Producing Tax Crime Information Not in Charges Originally Made Did Not Violate Rights (10/31/21)

Russian Bank Founder Sentenced for Crimes Related to Expatriation to Avoid Tax (10/30/21)

Former IRS Tax Advocate Employee Indicted for Tax Evasion and Tax Obstruction (10/21/21)

U.S. Sentencing Commission Judiciary Sentencing Information (“JSIN”) for Judges (10/17/21)

Court Sustains Willful FBAR Penalty for Two of Four Years (10/15/21)

On the Pandora Papers (10/11/21)

Plea Deal with Russian Bank Founder for Tax Perjury Requiring Payment of More than $500 Million (10/2/21)

TRAC Report on “Equal Justice and Sentencing Practices Among Federal District Court Judges” (9/30/21)

Indictments of Swiss Enablers for U.S. Tax Evasion through a "Singapore Solution;" One U.S. Taxpayer Guilty Plea (9/28/21)

ABA Tax Section Comments on Voluntary Disclosure Practice and Streamlined Filing Compliance Procedures (9/28/21)