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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FinCEN Notice 2020-2 to Make Virtual Currency Foreign Accounts FBAR Reportable (12/31/20; 1/16/21)

Fifth Circuit Denies Rehearing En Banc in Controversial Client Identity Privilege Case (12/23/20)

First Criminal Cases from Abusive Syndicated Conservation Easements (12/23/20; 12/29/20)

Court of Appeals Rejects Lawyer Defendant's Proffered Instruction that Cheek Requires Knowledge that Conduct Is Criminal (12/7/20)

Summons Enforced Against Prominent U.S. Director, Producer, Writer and Convicted Felon After OVDP Termination for Not Disclosing Foreign Indictment (12/7/20)

Eleventh Circuit Rejects a Marinello Claim that Nexus to Pending Proceeding Not Shown (12/6/20)

IRS Group Requests to Swiss FTA for Swiss Bank Customer Information Behind Aggregation Information Disclosures Under FATCA (12/6/20)

Bedrosian on Remand -- Held Bedrosian Acted Recklessly and thus Subject to FBAR Civil Willful Penalty (12/6/20)

Discussion of Criminal Tax Issues in Oral Argument in CIC Services (12/5/20)

In FBAR Collection Case, NYT and WSJ Articles on U.S. Offshore Efforts Admissible Against Avid Reader of the Publications (12/4/20)

Individual B, the Houston Attorney in the Smith NPA, Is Unmasked (12/1/20; 12/2/20)

Comisky Article on Tax Evasion and Money Laundering (11/26/20)

Third Circuit Sustains Application of Gun Possession Prohibition to Tax Felon (11/25/20)

Update on Brockman Indictment (11/11/20)

Thoughts on NonProsecution for Trump (11/9/20)

Smith NPA and the FBAR Costs (Fines or Penalties?) Described (11/6/20)

Robert Frank Editorial on Decline in Enforcement Resources and Tax Evasion (11/3/20)

Court of Appeals Finds No Harm Attorney's Failure to Assure Client Understood Relevant Conduct for Sentencing Loss Calculations (10/29/30)