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...
by Lynam Knott | Apr 9, 2012 | Criminal Fines, Department of Justice
We get questions all the time about situations that appear to involve tax fraud, but often it is unclear to the person asking the question exactly what activities rise to the level of tax fraud or tax evasion. So here’s a short primer on what tax fraud and...
by Lynam Knott | Jan 30, 2012 | Award Determinations, Criminal Fines, IRS Whistleblower Office, Whistleblower Awards
Congratulations to our associate, Erica Brady, for the publishing of her article, Does Tax Crime Pay (Whistleblowers)?, in the February 2012 edition of TAXES–The Tax Magazine published by CCH. She has previously blogged about criminal fines as tax whistleblower...
by Lynam Knott | Aug 2, 2011 | Criminal Fines
Congratulations to our associate, Erica Brady, for the publishing of her article, Are Criminal Fines “Collected Proceeds”?, in the Summer 2011 edition of the ABA Section of Taxation NewsQuarterly. She has previously blogged about criminal fines as tax...
by Hilary Lefko | May 16, 2011 | Award Determinations, Criminal Fines, Guidance, IRS Whistleblower Office
Last week, Ferraro Law Firm partner, Scott Knott, spoke at the IRS’s public hearing on Proposed Treasury Regulations on the definition of “collected proceeds” in the context of paying whistleblower awards under section 7623. Scott joined other...
by Lynam Knott | Apr 21, 2011 | Award Determinations, Criminal Fines, Guidance
PMTA 2010-60, Criminal Fines and Whistleblower Awards [PDF], is a line in the sand signaling that the IRS is willing to litigate whether criminal fines are properly included in “collected proceeds.” The Proposed Treasury Regulations [PDF] are...
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