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Tax Crimes

Pending appeal of criminal conviction motion doesn’t affect timing of restitution assessment

Pending appeal of criminal conviction motion doesn’t affect timing of restitution assessment

Chief Counsel Advice 201616011 In an emailed Chief Counsel Advice, IRS has concluded that the fact that an individual has a pending appeal of his motion to vacate his criminal conviction does not affect IRS’s ability to assess the amount of criminal restitution owed it under a court order. Background. 18 USC 3556 provides for mandatory […]

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Europe’s biggest nations join forces to end tax evasion

Europe’s biggest nations join forces to end tax evasion

WASHINGTON (Reuters) – Europe’s biggest nations launched a joint effort on Thursday to clamp down on tax evasion, responding to damaging revelations of financial wrongdoing by the rich and powerful in the so-called Panama Papers. The finance ministers of Britain, Germany, France, Italy and Spain agreed to share detailed data on the ownership of companies, […]

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Mo Money Tax Return Preparers Plead Guilty to Conspiracy to Defraud the United States and Filing False Tax Returns

Mo Money Tax Return Preparers Plead Guilty to Conspiracy to Defraud the United States and Filing False Tax Returns

According to the Department of Justice Press Release: Two tax return preparers pleaded guilty to one count of conspiracy to defraud the United States and one count of aiding and assisting in the preparation of a false tax return, announced Acting Assistant Attorney General Caroline D. Ciraolo of the Justice Department’s Tax Division and U.S. […]

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U.S. House tax writer pushes 2016 tax reform on foreign earnings

U.S. House tax writer pushes 2016 tax reform on foreign earnings

WASHINGTON (Reuters) – The U.S. House of Representatives’ top tax writer wants a vote this year on legislation moving the United States to a territorial-style tax system aimed at exempting the earnings of American companies abroad from U.S. taxation. International tax reform should be tackled as the first step toward a bigger rewrite of the […]

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Only one aiding/abetting penalty for false statements on retirement plan application

Only one aiding/abetting penalty for false statements on retirement plan application

Chief Counsel Advice 201531015 In Chief Counsel Advice, IRS has drawn several conclusions with respect to the Code Sec. 6701 aiding and abetting penalty. For example, it concluded that it can assess only one Code Sec. 6701 penalty against an individual who submits false documents in support of a retirement plan’s application for qualified status, […]

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Restitution paid to government as part of business crime plea deal was deductible

Restitution paid to government as part of business crime plea deal was deductible

PLR 201528026 In a private letter ruling, IRS has held that a principal in a business could deduct the amount he paid to the U.S. government as restitution, as part of a plea deal resulting from his pleading guilty to a crime committed in the course of his employment.  Click here for the PLR. Background. […]

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IRS Explains Its New Position On Civil Forfeiture In Structuring Cases

IRS Explains Its New Position On Civil Forfeiture In Structuring Cases

IRS Commissioner John Koskinen, testifying before the House Committee on Ways and Means Subcommittee on Oversight on Financial Transaction Structuring, has explained IRS’s new policy (first announced in October of 2014) under which it will no longer pursue the seizure and forfeiture of funds associated solely with “legal source” structuring cases (i.e., where the funds […]

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No deduction for restitution amount paid to avoid criminal prosecution

No deduction for restitution amount paid to avoid criminal prosecution

Chief Counsel Advice 201513003 In emailed Chief Counsel Advice (CCA), IRS has held that a payment a taxpayer made to the U.S., in lieu of proceedings that would result in criminal and/or civil forfeiture for fraud, was nondeductible as a fine or similar penalty notwithstanding that the payment was earmarked for restitution to the victims […]

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Former Miami-Dade County Employee Sentenced for Tax Evasion

Former Miami-Dade County Employee Sentenced for Tax Evasion

Former Miami-Dade County Employee Sentenced for Tax Evasion, as reported in the DOJ Press Release. A Coral Gables, Florida, resident and former employee of the General Services Administration (GSA) of Miami-Dade County was sentenced to serve 51 months in prison for tax evasion to be followed by three years of supervised release, and ordered to pay […]

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California Investment Manager Sentenced to 225 Months in Prison for $33 Million Fraud Scheme

California Investment Manager Sentenced to 225 Months in Prison for $33 Million Fraud Scheme

California Investment Manager Sentenced to 225 Months in Prison for $33 Million Fraud Scheme, as reported in the DOJ Press Release. A California investment manager was sentenced yesterday to serve 225 months in prison for orchestrating a $33 million Ponzi scheme resulting in $15.2 million in losses to investors. Assistant Attorney General Leslie R. Caldwell […]

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Las Vegas Man Sentenced to Prison for Conspiring to Submit False Federal Income Tax Returns

Las Vegas Man Sentenced to Prison for Conspiring to Submit False Federal Income Tax Returns

As reported in the DOJ press release, a Las Vegas man was sentenced to serve 15 months in prison to be followed by three years of supervised release and ordered to pay $192,632 in restitution to the Internal Revenue Service (IRS), announced Acting Deputy Assistant Attorney General Larry J. Wszalek for the Justice Department’s Tax […]

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Kentucky Businessman Pleads Guilty in Manhattan Federal Court to $53 Million Tax Scheme and Massive Fraud That Involved the Bribery of Bank Officials

Kentucky Businessman Pleads Guilty in Manhattan Federal Court to $53 Million Tax Scheme and Massive Fraud That Involved the Bribery of Bank Officials

U.S. Attorney Preet Bharara for the Southern District of New York and Deputy Assistant Attorney General David A. Hubbert for the Tax Division of the Department of Justice announced that Wilbur Anthony Huff, a Kentucky businessman, pleaded guilty today in Manhattan federal court to various tax crimes that caused more than $50 million in losses […]

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Utah Accountant Sentenced for Filing Over $9 Million in False Tax Refund Claims and $300 Million Fictitious Financial Instrument

Utah Accountant Sentenced for Filing Over $9 Million in False Tax Refund Claims and $300 Million Fictitious Financial Instrument

As reported in the DOJ Press Release, a Heber City, Utah, man was sentenced to serve 78 months in prison for filing false claims for income tax refunds and for filing a fictitious financial instrument, announced Acting Deputy Assistant Attorney General Larry J. Wszalek for the Department’s Tax Division and the Internal Revenue Service (IRS). […]

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Tax Return Preparers Convicted of Assisting Wealthy Clients Hide Millions in Secret Offshore Accounts at Israeli Banks

Tax Return Preparers Convicted of Assisting Wealthy Clients Hide Millions in Secret Offshore Accounts at Israeli Banks

As reported in the DOJ Press Release, a federal jury sitting in Los Angeles convicted two California tax return preparers of one count of conspiracy to defraud the Internal Revenue Service (IRS) and two counts  of willfully failing to file a Report of Foreign Bank and Financial Accounts (FBAR) announced Acting Deputy Assistant Attorney General […]

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Former New Jersey Chiropractor Sentenced to Prison for Fraud

Former New Jersey Chiropractor Sentenced to Prison for Fraud

As reported in the DOJ Press Release, a  man formerly of Neptune, New Jersey, was sentenced in the U.S. District Court for the District of New Jersey to serve 54 months in prison to be followed by five years of supervised release, the Justice Department and the Internal Revenue Service (IRS) announced. In February 2014, a […]

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Massachusetts Businessman Involved in Adult Entertainment Industry Pleads Guilty to Tax Evasion

Massachusetts Businessman Involved in Adult Entertainment Industry Pleads Guilty to Tax Evasion

As reported in the DOJ Press Release, a Massachusetts businessman pleaded guilty to tax evasion for using nominee entities to hide ownership and control over his businesses and assets from the Internal Revenue Service (IRS), announced Acting Deputy Assistant Attorney General Larry J. Wszalek for the Justice Department’s Tax Division and U.S. Attorney Carmen M. […]

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IRS Targets U.S. Tax Cheats by Summoning Records from Shipping and Financial Service Providers

IRS Targets U.S. Tax Cheats by Summoning Records from Shipping and Financial Service Providers

Click here to view the DOJ press release dated Dec. 19, 2014. Click here to view the “[Proposed] Order Granting Ex Parte Petition for Leave to Serve “John Doe” Summonses.” A U.S. district court has authorized IRS to serve “John Doe” summonses to eight entities in the shipping and financial services industries in order to identify the […]

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Six Corporate Executives And Six Corporate EntitiesIndicted For Orchestrating A $500 Million Offshore Asset Protection, Securities Fraud, And Money Laundering Scheme

Six Corporate Executives And Six Corporate EntitiesIndicted For Orchestrating A $500 Million Offshore Asset Protection, Securities Fraud, And Money Laundering Scheme

As reported in the DOJ Press Release, Six Corporate Executives And Six Corporate EntitiesIndicted For Orchestrating A $500 Million Offshore Asset Protection, Securities Fraud, And Money Laundering Scheme.  The case is E.D.N.Y. Docket No. 14-CR-476 (ILG). Defendants Created Three Brokerage Firms in Belize to Assist U.S. Citizens in Fraudulent Manipulation Schemes of Publicly Traded Companies, […]

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United States Congressman Michael Grimm Pleads Guilty to Causing the Filing of a False and Fraudulent Tax Return

United States Congressman Michael Grimm Pleads Guilty to Causing the Filing of a False and Fraudulent Tax Return

As reported in the DOJ Press Release, on December 23, 2014, United States Congressman Michael Grimm pleaded guilty at the federal courthouse in Brooklyn, New York, to aiding and assisting the preparation of a false tax return.  Since 2011, Grimm has served as a member of the United States House of Representatives representing New York’s 11th […]

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Pittsburg Resident Charged In Tax Fraud Scheme

Pittsburg Resident Charged In Tax Fraud Scheme

Pittsburg Resident Charged In Tax Fraud Scheme, as reported by the DOJ. San Francisco – Ebony Standifer, was charged with conspiracy to file false claims, wire fraud, and aggravated identity theft, announced United States Attorney Melinda Haag and Internal Revenue Service, Criminal Investigation, Acting Special Agent in Charge Thomas McMahon. According to the indictment, between […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney