Department of Justice Archives

DOJ Tax Division is interested in whistleblower information, but risks of disclosure should be discussed with counsel prior to disclosure.

by Lynam Knott | Dec 9, 2016 | Criminal Fines, Department of Justice

Caroline Ciraolo, Principle Deputy Assistant Attorney General, Department of Justice Tax Division, made clear the importance of whistleblower counsel while speaking at the American Bar Association’s National Institute on Criminal Tax Fraud and Institute on Tax...

Tax Court finds it has Jurisdiction to Review Determinations Where Information was Provided Before and After The Effective Date of Section 7623(b).

by Lynam Knott | Jun 5, 2014 | Administration of Whistleblower Claims, Award Determinations, Department of Justice, Guidance, Judicial Review

The Tax Court held that it has jurisdiction to review the IRS’s whistleblower claims award determinations where the informant has alleged that they provided significant information to the IRS before and after December 20, 2006, the effective date of section...

Use of whistleblower information in tracking down unreported offshore accounts acknowledged by DOJ.

by Lynam Knott | May 12, 2014 | Department of Justice, Offshore Assets, Voluntary Disclosure Initiative, Whistleblower Awards

Kathryn Keneally, Assistant Attorney General, Tax Division of the Department of Justice, acknowledged that the Department of Justice had used information provided by whistleblowers in tracking down unreported offshore bank accounts held by United States citizens while...

Whistleblowers Still Needed to End Bank Secrecy Protection for Tax Evaders

by Lynam Knott | Jan 13, 2014 | Department of Justice, Offshore Assets, Taxpayer Underpayment

Last week a Swiss Federal Administrative Court rejected a U.S. government request for banking data on U.S. clients of Swiss bank Julius Baer. This ruling related to a group request for U.S. taxpayers with undisclosed accounts filed on a no-name basis. ...

As IRS and the Department of Justice attempt to do more with less, whistleblowers could be the key to continuing to combat tax shelters.

by Lynam Knott | Nov 6, 2013 | Aggressive Tax Positions, Criminal Fines, Department of Justice, Taxpayer Underpayment

Tax shelters are an on-going battle for the IRS and the Department of Justice with large amounts of money at stake for the government, the taxpayer, and possibly for a knowledgeable whistleblower. Tax shelter cases involve schemes that attempt to manipulate...

IRS says whistleblower law a “game changer” in their efforts to combat offshore evasion.

by Lynam Knott | Dec 18, 2012 | Aggressive Tax Positions, Department of Justice, Offshore Assets

Tax practitioners and government officials recently came together at the American Bar Association International Tax Enforcement Conference in New York to discuss international tax enforcement rules and procedures. Among the topics of discussion was the federal...

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