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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Third Circuit Case Discussing Difference Between Willfully Element for Tax Crimes (Cheek Willfulness) and for General Crimes with Willfully Element (1/30/21)

Tax Court Opinion on Various Aspects of Collection Activity for RBAs and Coordination with DOJ (1/28/21)

More on Willful Blindness (1/28/21)

Court Amends Restitution to Reduce Restitution for Amounts For Years Other Than Years for Counts of Conviction (1/20/21)

Outstanding Article on Current State of IRS Voluntary Disclosure Practice (1/16/21)

Another District Court Holds FBAR Nonwillful Civil Penalty Is Per Form Rather Than Per Account (1/15/21)

Third Circuit Discussion on Violation of Legal Duty with Other Reasonable Interpretations of Duty (1/13/21)

Deloitte and Tax Analysts Open Tax Analysts Library to Public Without Subscription (1/11/21)

Corporate Transparency Act – Beneficial Ownership of Shell Corporations Must Be Disclosed (1/8/21; 2/11/21)

Whistleblower FYE 2020 Report (1/6/21)

D.C. Circuit Reverses Trial Court Because the Allen Charge, in Context, Was Coercive, But Affirms on Brady Issue (1/6/21)

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)