by Lynam Knott | Dec 18, 2012 | Administration of Whistleblower Claims, Award Determinations, Criminal Fines, Guidance, IRS Whistleblower Office
Proposed Treasury Regulations for the IRS whistleblower program were released on December 14, 2012. These regulations cover many issues and deserve a complete reading; however, below is a short outline of what each section of the proposed regulations covers....
by Lynam Knott | Oct 29, 2012 | Administration of Whistleblower Claims, Award Determinations, IRS Whistleblower Office, Whistleblower Awards
We are excited to share some good news … the IRS has awarded $38,037,899 to one of our clients for providing information about a tax avoidance scheme perpetrated by one of the nation’s largest corporations. We respect our client’s wishes...
by Lynam Knott | Oct 10, 2012 | Award Determinations, IRS Whistleblower Office, Judicial Review
The Tax Court dismissed a whistleblower’s complaint that challenged the IRS’s decision not to act on the whistleblower’s information. In Raymond Cohen v. Commissioner of Internal Revenue, 139 T.C. No. 12 (October 9, 2012), the Tax Court holds...
by Lynam Knott | Sep 11, 2012 | Award Determinations, IRS Whistleblower Office, Offshore Assets
Congratulations to Brad Birkenfeld for receiving a $104 million award from the IRS for turning in UBS for their offshore banking practices. Kudos to Steve Kohn and Dean Zerbe, his counsel since 2009 on this matter. It appears that Birkenfeld’s award...
by Lynam Knott | Jul 31, 2012 | Administration of Whistleblower Claims, Award Determinations, Guidance, IRS Whistleblower Office, Whistleblower Awards
An interesting letter was released last night from IRS Commissioner Shulman to Senator Grassley. Commissioner Shulman’s letter says more about what is in the pipeline for large whistleblower case award determinations than any statement the IRS has made to...
by Lynam Knott | Jul 18, 2012 | Administration of Whistleblower Claims, Award Determinations, Criminal Fines, Guidance, Voluntary Disclosure Initiative, Whistleblower Awards
Tax Analysts recently released a Chief Counsel Memorandum dated April 23, 2012, stating that the IRS cannot pay a section 7623(b) award on recoveries from the failure to report a foreign bank account commonly referred to as “FBAR” penalties. While we...
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