Several months ago, we reported on the Internal Revenue Service (IRS) promulgating its final guidance for corporations required to file uncertain tax position (UTP) statements. The initial deadline for corporations with total assets equal to or exceeding $100 million to file its 2010 taxes with Schedule UTP, “Uncertain Tax Position Statement,” is fast approaching. Yet despite this formal guidance, IRS answers to FAQs, and a blogosphere full of information from tax practitioners, PricewaterhouseCoopers LLP (PwC) reports that companies are still facing major uncertainties with respect to their UTP reporting issues.
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2011-04-26 12:08:072026-01-07 14:28:21Companies Still Grappling with UTP Reporting Issues
The United States Justice Department, on behalf of IRS, has asked a federal judge to issue a “John Doe” summons on the California Board of Equalization requiring the board to turn over records of property transfers for little or no consideration (In Re the tax liabilities of John Does, E.D. Cal., No. 2:10-mc-00130-MCE-EFB, filed 12/27/11).
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2011-04-26 12:04:412014-11-10 18:20:34United States Government Requests US District Court to Release Property Tax Records from California Board of Equalization
Federal prosecutors brought criminal charges in 1,250 tax cases in 2010, a 25.3% jump from 2001. Criminal tax prosecution recommendations by the Criminal Investigation Division of the IRS reached a high of 1,507, up 50.4% from 2001. The data is from Transactional Records Access Clearinghouse, a data research and distribution organization.
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2011-04-25 07:34:522014-11-10 18:20:34Federal Prosecution of Tax Crimes up 25%
TaxMasters, a Houston-based publicly-traded company that bills itself as helping people having trouble with the IRS, stands accused in two states of deceptive business practices. Texas and Minnesota have both filed suit, with the former alleging that the company engages in “false, misleading, and deceptive acts and practices” and the latter filing a civil action accusing TaxMasters of fraud and deception. Minnesota’s Attorney General was quoted by ABC News saying, “[t]his is a company which is taking advantage of people . . . when people see it on TV, they do believe in it.” According to the ABC report, TaxMasters is spending millions on advertising on cable channels such as CNN and Fox News.
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2011-04-21 08:55:402014-11-10 18:20:34Trouble For TaxMasters
On April 7, 2011, the U.S. District Court for the Northern District of California, in case # 4:11-cv-1686, granted the Governments ex parte motion to issue “John Doe” summons to […]
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2011-04-19 09:03:302025-12-09 14:20:40U.S. District Court Grants Government’s Motion to Issue John Doe Summons to HSBC
The debate on stem cells continues to raise controversy and impact science and discovery. The latest twist involves Michigan state lawmakers who recently proposed requiring each state public university to […]
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2011-04-19 08:55:572025-12-09 14:20:40Michigan lawmakers stir controversy proposing State Universities to report stem-cell use
Under certain circumstances, it is a defense to a charge of willful criminal conduct that the defendant relied on the advice of a lawyer in committing the offense.
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2011-04-19 08:51:052025-12-09 14:20:39Former GlaxoSmithKline in house counsel re-indicted
On April 15, 2011, federal prosecutors indicted eleven people in connection with their involvement in running PokerStars, Full Tilt Poker, and Absolute Poker, three of the largest internet poker sites in the United States. The Department of Justice has charged these individuals with multiple charges including violations of the Unlawful Internet Gambling Enforcement Act (“UIGEA”), conspiracy to commit bank fraud and wire fraud, operating an illegal gambling business, and money laundering conspiracy. A copy of the indictment can be read here.
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2011-04-18 10:03:152026-01-07 15:36:01Department of Justice Shuts Down Three of the Largest Internet Poker Sites in US, Charge Owners with Unlawful Internet Gambling, Fraud, Money Laundering, and Seek to Recover $3 Billion in Civil Penalties.
On April 13, 2011, U.S. Food and Drug Administration (FDA) Commissioner Margaret Hamburg testified before the U.S. House of Representative Energy and Commerce Subcommittee on Oversight and Investigations regarding the Agency’s implementation of the new Predictive Risk-Based Evaluation for Dynamic Import Compliance Testing (PREDICT). PREDICT is a Web-based system designed to target inspections strategically based on risk factors chosen by the FDA.
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2011-04-18 09:25:062014-11-10 18:20:34FDA Commissioner Testifies on FDA’s Screening Efforts at the Border
In Notice 2011-31, available here, the IRS stated that beginning on March 28, 2011, “the recently published final FBAR regulations will be effective, and should be referenced, along with the […]
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2011-04-18 09:07:212025-12-09 14:15:08IRS Says Taxpayers Should Review Revised FBAR Instructions When Preparing Income Tax Returns
Companies Still Grappling with UTP Reporting Issues
Several months ago, we reported on the Internal Revenue Service (IRS) promulgating its final guidance for corporations required to file uncertain tax position (UTP) statements. The initial deadline for corporations with total assets equal to or exceeding $100 million to file its 2010 taxes with Schedule UTP, “Uncertain Tax Position Statement,” is fast approaching. Yet despite this formal guidance, IRS answers to FAQs, and a blogosphere full of information from tax practitioners, PricewaterhouseCoopers LLP (PwC) reports that companies are still facing major uncertainties with respect to their UTP reporting issues.
United States Government Requests US District Court to Release Property Tax Records from California Board of Equalization
The United States Justice Department, on behalf of IRS, has asked a federal judge to issue a “John Doe” summons on the California Board of Equalization requiring the board to turn over records of property transfers for little or no consideration (In Re the tax liabilities of John Does, E.D. Cal., No. 2:10-mc-00130-MCE-EFB, filed 12/27/11).
Federal Prosecution of Tax Crimes up 25%
Federal prosecutors brought criminal charges in 1,250 tax cases in 2010, a 25.3% jump from 2001. Criminal tax prosecution recommendations by the Criminal Investigation Division of the IRS reached a high of 1,507, up 50.4% from 2001. The data is from Transactional Records Access Clearinghouse, a data research and distribution organization.
Trouble For TaxMasters
TaxMasters, a Houston-based publicly-traded company that bills itself as helping people having trouble with the IRS, stands accused in two states of deceptive business practices. Texas and Minnesota have both filed suit, with the former alleging that the company engages in “false, misleading, and deceptive acts and practices” and the latter filing a civil action accusing TaxMasters of fraud and deception. Minnesota’s Attorney General was quoted by ABC News saying, “[t]his is a company which is taking advantage of people . . . when people see it on TV, they do believe in it.” According to the ABC report, TaxMasters is spending millions on advertising on cable channels such as CNN and Fox News.
U.S. District Court Grants Government’s Motion to Issue John Doe Summons to HSBC
On April 7, 2011, the U.S. District Court for the Northern District of California, in case # 4:11-cv-1686, granted the Governments ex parte motion to issue “John Doe” summons to […]
Michigan lawmakers stir controversy proposing State Universities to report stem-cell use
The debate on stem cells continues to raise controversy and impact science and discovery. The latest twist involves Michigan state lawmakers who recently proposed requiring each state public university to […]
Former GlaxoSmithKline in house counsel re-indicted
Under certain circumstances, it is a defense to a charge of willful criminal conduct that the defendant relied on the advice of a lawyer in committing the offense.
Department of Justice Shuts Down Three of the Largest Internet Poker Sites in US, Charge Owners with Unlawful Internet Gambling, Fraud, Money Laundering, and Seek to Recover $3 Billion in Civil Penalties.
On April 15, 2011, federal prosecutors indicted eleven people in connection with their involvement in running PokerStars, Full Tilt Poker, and Absolute Poker, three of the largest internet poker sites in the United States. The Department of Justice has charged these individuals with multiple charges including violations of the Unlawful Internet Gambling Enforcement Act (“UIGEA”), conspiracy to commit bank fraud and wire fraud, operating an illegal gambling business, and money laundering conspiracy. A copy of the indictment can be read here.
FDA Commissioner Testifies on FDA’s Screening Efforts at the Border
On April 13, 2011, U.S. Food and Drug Administration (FDA) Commissioner Margaret Hamburg testified before the U.S. House of Representative Energy and Commerce Subcommittee on Oversight and Investigations regarding the Agency’s implementation of the new Predictive Risk-Based Evaluation for Dynamic Import Compliance Testing (PREDICT). PREDICT is a Web-based system designed to target inspections strategically based on risk factors chosen by the FDA.
IRS Says Taxpayers Should Review Revised FBAR Instructions When Preparing Income Tax Returns
In Notice 2011-31, available here, the IRS stated that beginning on March 28, 2011, “the recently published final FBAR regulations will be effective, and should be referenced, along with the […]