On April 17, 2020, in United States v. Costanzo, No. 18-10291, 2020 U.S. App. LEXIS 12287 (9th Cir. April 17, 2020), the Ninth Circuit upheld the conviction of a defendant under the “sting” money laundering provision, 18 U.S.C. §
Tax Controversy Posts
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Employment Taxes During the COVID-19 Pandemic
The COVID-19 pandemic has changed a lot of things, and
employment taxes are no exception. To help you understand the present state of
employment taxes, I will start by outlining how the employment tax system
normally operates.
How Employment Taxes…
Employment Tax Aspects of the Coronavirus Response Act
The Families First Coronavirus Act (the “Act”) has significant employment law implications, as it imposes new leave provisions under the Emergency Paid Sick Leave Act and the Emergency Family and Medical Leave Expansion Act, summarized here. The Act also…
FinCEN Imposes Civil Money Penalty on Former Bank Officer for Failing to Adequately Staff Bank’s AML Compliance Function and for Capping Bank’s Suspicious Activity Reports
In February 2018, Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) and the Office of the Comptroller of the Currency imposed a $185 million civil money penalty on U.S. Bank N.A. (Bank) for willful violations of the Bank Secrecy Act…
Pay or Stay: International Travel Restrictions for Delinquent Taxpayers
Individuals with a “seriously delinquent tax debt” may face limitations on their ability to travel abroad, as the Commissioner of Internal Revenue can certify the taxpayer’s status to the Secretary of the Treasury, who “shall transmit such certification to the…
Exempt Organizations: Public Charities and Real Estate
In Pennsylvania, charities must meet two overlapping tests to establish their right to a tax exemption. First, the institution must establish that it is a purely public charity within the meaning of Article VIII, Section 2(a)(v) of the Pennsylvania Constitution,…
State and Local Taxation: A Look at Uniformity Under Valley Forge
The Pennsylvania Constitution requires that taxes be uniform: “All taxes shall be uniform, upon the same class of subjects, within the territorial limits of the authority levying the tax, and shall be levied and collected under general laws.” Pa. Const.…
The Establishment Clause Meets the Anti-Injunction Act
The First Amendment provides that “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof.” U.S. Const., amend. I.Churches qualify for an exemption from taxation under section 501(c)(3) of the Internal Revenue Code, as…
Tax Procedure: Taxpayers Should Not Expect Equity
Equitable doctrines are generally read into most federal statutes of limitations. Equitable tolling typically applies “when the prospective plaintiff simply does not have and cannot with due diligence obtain information essential to bringing a suit.” Wolin v. Smith Barney Inc.,…
False Claims Act Relators Cannot Intervene in Criminal Proceedings that Result from Relator’s Disclosure to Government, Third Circuit Rules
On October 28, 2019, the Third Circuit in United States v. Wegeler, No. 17-1717, 2019 U.S. App. LEXIS 32282, addressed an issue of first impression, holding that a False Claims Act (FCA) relator whose information resulted in a criminal…