• DEALING WITH TAX DEBTS IN BANKRUPTCY AFTER THE BAPCPA

    The intended beneficiaries of the humorously titled “Bankruptcy Abuse Prevention and Consumer Protection Act of 2005″ (BAPCPA) were the big banks and credit card companies — lobbying pays. The new law also helps those with alimony and child support awards. But a third winner was your friendly, neighborhood tax collector. In general, the BAPCPA makes […]

  • TAX FRAUD INVESTIGATIONS – A PROCEDURAL ROADMAP Part I

    I. Introduction An IRS fraud investigation is a harrowing experience, not only for the corporate officers, directors and employees who are the subject of the investigation, but for the corporation’s legal advisors as well. The process many begin innocuously with a routine civil tax examination, or with the jolting arrival of a grand jury subpoena. […]

  • TAX FRAUD INVESTIGATIONS – A PROCEDURAL ROADMAP Part II

    I. Introduction In the last issue of the Corporate Criminal Liability Reporter, Spring 1988, we described the process involved in IRS criminal investigations — how they begin, the cast of players, the investigatory techniques used, and the manner in which evidence is summarized for subsequent use in reviewing and prosecuting the case. In this second […]

  • VOLUNTARY DISCLOSURE OF OFFSHORE ACCOUNTS

    Things are getting ever more uncomfortable for U.S. taxpayers holding undisclosed offshore bank and investment accounts. And in the wake of the very public fight between the Internal Revenue Service and Union Bank of Switzerland (UBS), it is quite possible that one of your clients will reveal to you that he has an offshore account […]

  • OFFERS IN COMPROMISE AFTER TIPRA

    After the Bankruptcy Abuse Prevention and Consumer Protection Act you thought it couldn’t get any worse for your tax delinquent clients? Wrong again. The latest Congressional gift to the IRS Collection Division is Section 509 of the Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA). One must at least give grudging credit to the […]