Treasury Report Shows Huge Tax Gap for the Top 1% of Taxpayers
The US Treasury just released a Report authored by Natasha Sarin, Deputy Assistant Secretary for Economic Policy, titled "The Case for a Robust Attack on the Tax Gap" , and it provides new information on what the Government views as to what constitutes the "Tax Gap"...
Treasury is Looking to Expand Tax Enforcement – Where Does that Leave Whistleblowers?
The Treasury Department just released a 22 page report that outlines an initiative which aims to generate an additional $700 billion of revenue over the next 10 years, and this initiative is linked to spending an additional $80 billion on the Internal Revenue Service...
IRS Whistleblower Office FY 2020 Report to Congress highlights the need to have a strong submission presentation.
The IRS Whistleblower Office has published its Annual Report to Congress for Fiscal Year 2020. The annual report reflects back on the fiscal year that ended on September 30, 2020. During Fiscal Year 2020, the IRS Whistleblower Office endured delays due to COVID-19,...
Top 10 Myths of the Tax Whistleblower Program
Our tax whistleblower attorneys know how to deal with the IRS. They know what types of information and documentation the IRS needs; they know how and to whom that evidence should be presented in order to maximize your reward. If you have information about large-scale...
What Does an Uptick in Tax Enforcement Mean to Whistleblowers?
Jesse Eisinger just did a piece today in the New York Times about how we might soon be seeing an increase in the enforcement of our tax laws after an eight year decline in audit and prosecution of tax cases by the IRS. To recap: Congress has been cutting the IRS’s...
Statutory changes show big results in the Whistleblower Office in FY 2018
The IRS Whistleblower Office released it FY 2018 Report to Congress today. The report comes out one year after Congress amended section 7623 in the Bipartisan Budget Act of 2018, which clarified the definition of proceeds includes non-Title 26 amounts such as...
Getting an FBAR Based Award – Not as Simple as it Looks
Today the GAO released a study wherein they looked at the ability of the IRS to track and then pay awards on monies that are collected by the Government relating to “FBAR” violations. Recall that FBAR stands for the “Reports of Foreign Bank and Financial Accounts” ...
IRS Enforcement Actions Still at Record Lows
A report just released by TIGTA (the Treasury Inspector General for Tax Administration) shows that once again IRS audits of taxpayers are in decline. Enforcement revenues are slightly up this year, but TIGTA says this is due to a small number of large corporate...
The Ferraro Law Firm Attends the 42nd Annual Federal Bar Association Tax Law Conference
On March 9th, Tax Partner Scott Knott and I attended the Federal Bar Association Tax Law Conference in Washington, D.C. Known colloquially as the “inside the beltway tax conference,” many high ranking federal government employees from DOJ, Treasury, and the IRS were...
Filing Season Fraud and Whistleblowers
We get absolutely deluged with hundreds of calls a day during tax return filing season about all kinds of fraud, particularly identity related scams and claiming child exemptions improperly. In 2016, there was a 400% increase in tax related phishing and malware...
Whistleblower Office Annual Report for 2017 Reveals the Program’s Challenges and Opportunities.
Happy New Year! The new year brings a time to reflect back on the past year, on things that went well, things that went not-so-well, and how you would like to do things going forward. In the spirit of looking back over the last year, the IRS Whistleblower Office...
Rapidly Growing SEC Whistleblower Program Creates Opportunities for Tax Whistleblowers
Many tax fraud cases also involve securities law violations. For instance, corporations engaged in tax evasion may also be creating fraudulent financials or offering securities to investors by providing misleading or untruthful information. The most common...
Senator Grassley’s Amendment to Clarify the Definition of “Collected Proceeds” is Added to the Senate Tax Mark Up
Late on November 16th, the Senate Finance Committee voted to approve its iteration of the Tax Cuts and Jobs Act, passing the measure on a party-line 14-12 vote. The full version can be found here. Of particular interest to our readers here is one of the...
Fiscal 2018 Sequestration to Reduce IRS Whistleblower Awards by 6.6 Percent. . . For Now
The IRS announced that whistleblower awards paid under section 7623 on or after October 1, 2017 and on or before September 30, 2018, will continue to be reduced by the “sequestration reduction rate”, which has now been lowered slightly to 6.6 percent. The 6.6 percent...
Blowing the Whistle on State Sales and Use Tax Violations.
There seems to be as many ways to cheat on your taxes as there are taxes. State sales and use taxes are no different. Some may not realize it but sales and use taxes are two different taxes. Sales tax is usually collected by the seller at the time...
Tax Court retains jurisdiction while Whistleblower Office issues revised determination, denies IRS Motion for Remand.
On July 28, 2017, the Tax Court denied the April 14, 2016 Joint Motion to Remand the case to the IRS Whistleblower Office. In the joint motion, the parties represented that the IRS Whistleblower Office had reconsidered its determination. The Tax Court...
U.S. Tax Court: The section 7623(b)(5)(B) phrase “amounts in dispute” is not specifically limited to only those amounts directly or indirectly attributable to the whistleblower information.
The United States Tax Court held in Smith v. Commissioner of Internal Revenue that the threshold limitation found in section 7623(b)(5) have “clear meaning” and were intended to limit the nondiscretionary award regime to larger cases. The Court...
Tax Court holds that waiver of right to seek judicial review in accepting an award is binding.
Today the Tax Court issued an opinion, Whistleblower 4496-15W v. Commissioner of Internal Revenue, granting the IRS’s motion for summary judgement. In this case, the informant had received a preliminary award determination for an award of $2,954,933. ...
IRS Formalizes Protection of Whistleblower Identities by Chief Counsel Attorneys.
In the tax practitioner version of “Were I King,” nearly every one of us has had that moment where we smack our head at something the IRS does or does not do and think, “the IRS should just ….” It is a form of armchair...
Fortune 500 Companies Are Avoiding $767 Billion in U.S. Taxes.
A recent study by the Institute on Taxation and Economic Policy details how Fortune 500 Companies are holding a record $2.6 trillion offshore, thereby avoiding $767 billion in U.S. taxes. While we believe much of this amount is the result of lawful tax planning...