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Whistleblower Awards

Accountants, journalist face tax leaks trial in Luxembourg

Accountants, journalist face tax leaks trial in Luxembourg

LUXEMBOURG (Reuters) – Two former employees of accountancy giant PwC go on trial in Luxembourg on Tuesday along with a French journalist, accused of leaking details of corporate tax deals that have fuelled global demands for reform. The case, coming 18 months after revelations dubbed LuxLeaks sparked accusations the Grand Duchy conspired with multinational companies to deprive […]

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Tax Court – FBAR civil penalties aren’t taken into account in $2 million whistleblower threshold

Tax Court – FBAR civil penalties aren’t taken into account in $2 million whistleblower threshold

Whistleblower 22716-13W, (2016) 146 TC No. 6 The Tax Court has concluded that penalties for failing to file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (Foreign Bank Account Report or FBAR) under 31 U.S.C. sec. 5321(a) are not “additional amounts” for purposes of the $2,000,000 nondiscretionary award threshold under Code Sec. […]

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Washington Alert – IRS appeals loss in Altera Corp.; IRS Whistleblower Awards on the rise; Reminder for Health Coverage Tax Credit; IRS’s Collection function was responsible for generating $35.7 billion in revenue during FY 2015

Washington Alert – IRS appeals loss in Altera Corp.; IRS Whistleblower Awards on the rise; Reminder for Health Coverage Tax Credit; IRS’s Collection function was responsible for generating $35.7 billion in revenue during FY 2015

IRS has appealed its loss in Altera Corp, (2015) 145 TC No. 3, to the Ninth Circuit. In the earlier case, the Tax Court invalidated the requirement in 2003 final regs that related parties entering into qualified cost sharing arrangements are required to share stock-based compensation costs under Code Sec. 482. The Tax Court held […]

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Whistleblower sues Viacom, alleges Ninja Turtles tax fraud plan

Whistleblower sues Viacom, alleges Ninja Turtles tax fraud plan

NEW YORK (Reuters) – Viacom Inc was sued by a former vice president who said the media company fired her in retaliation for opposing its alleged plan to illegally avoid paying U.S. taxes on the international licensing rights for Teenage Mutant Ninja Turtles. In a complaint filed on Tuesday in Manhattan federal court, Nataki Williams […]

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IRS announces sequestration reduction of whistleblower awards issued in FY 2016

IRS announces sequestration reduction of whistleblower awards issued in FY 2016

In the latest issue of e-News for Tax Professionals, IRS has announced that, for the 2016 fiscal year (FY), whistleblower awards issued under Code Sec. 7623 will be reduced by 6.8%. This reduction is a required “sequestration” spending cut under the Balanced Budget and Emergency Deficit Reduction Act of ’85, as amended. Background on whistleblower awards. Under Code […]

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Tax Court: whistleblowers are entitled to production of info related to denial of award

Tax Court: whistleblowers are entitled to production of info related to denial of award

Whistleblower One 10683W, et al, (2015) 145 TC No. 8 The Tax Court, ruling against IRS, has granted a group of whistleblowers’ motion to compel production of certain discovery requests relevant to IRS’s denial of an award based on information they provided to it. The Court rejected IRS’s argument that the information was outside of […]

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Washington Alert – DHS investigates inverted corporations; IRS Whistleblower Office receives lots of attention; U.S. & Vietnam sign accord; U.S. & India sign IGA; JCT Report on Excise Taxes

Washington Alert – DHS investigates inverted corporations; IRS Whistleblower Office receives lots of attention; U.S. & Vietnam sign accord; U.S. & India sign IGA; JCT Report on Excise Taxes

A bicameral group of seven Democrats on July 9 called on the chief watchdog of the Department of Homeland Security (DHS) to investigate the possible violation of “multiple federal prohibitions on contracting with inverted corporations.” (Letter to John Roth, Office of Inspector General, Department of Homeland Security) The letter referred to a recent article which […]

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IRS letter that it was rethinking whistleblower award denial didn’t end Court’s jurisdiction

IRS letter that it was rethinking whistleblower award denial didn’t end Court’s jurisdiction

Ringo, (2014) 143 TC No. 15 The Tax Court has ruled that it had jurisdiction to hear a claim for a whistleblower award where the taxpayer filed an application for an award, IRS sent the taxpayer a letter denying his award claim, the taxpayer timely filed a Tax Court petition, and then IRS sent another […]

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IRS letter to whistleblower was a “determination” for Tax Court jurisdiction purposes

IRS letter to whistleblower was a “determination” for Tax Court jurisdiction purposes

Comparini, (2014) 143 TC No. 14 The Tax Court has ruled that it had jurisdiction to hear a claim for a whistleblower award where the whistleblowers filed their Tax Court petition within 30 days of receiving a letter from IRS that the Court ruled was a “determination” by IRS. The Court also concluded that the […]

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Whistleblower Payment Awarded to Auditing and Compliance Professional

Whistleblower Payment Awarded to Auditing and Compliance Professional

The SEC awarded $300,000 to a whistleblower who reported wrongdoing to the agency after the company took no action when the employee first reported it internally. This is the first time that a whistleblower award was given to an employee in compliance and audit function at a company. The SEC on August 29, 2014, announced […]

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Tax Court Case: $2 million requirement in whistleblower cases is affirmative defense, not jurisdictional bar

Tax Court Case: $2 million requirement in whistleblower cases is affirmative defense, not jurisdictional bar

Lippolis, (2014) 143 TC No. 201 The Tax Court has concluded that Code Sec. 7623(b)(5)(B), which limits the whistleblower award rules of Code Sec. 7623(b) (including Code Sec. 7623(b)(1)’s mandatory award provision) to cases where the total amount in dispute exceeds $2 million, is an affirmative defense to be raised and proven by IRS and […]

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IRS issues comprehensive final regs on whistleblower program

IRS issues comprehensive final regs on whistleblower program

T.D. 9687, 08/07/2014; Reg. § 301.6103(h)(4)-1, Reg. § 301.7623-1, Reg. § 301.7623-2, Reg. § 301.7623-3, Reg. § 301.7623-4 IRS has issued final regs that provide comprehensive guidance for IRS’s Code Sec. 7623 award program (i.e., whistleblower awards). The final regs provide guidance on: (1) the submission of information and filing of claims for award; (2) […]

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Tax Court has jurisdiction to review whistleblower claim

Tax Court has jurisdiction to review whistleblower claim

Whistleblower 11331-13W, (2014) 142 TC No. 21. The Tax Court has concluded that it has jurisdiction to review IRS’s whistleblower claim award determinations where a whistleblower alleged that he had provided information to IRS before and after the effective date of Code Sec. 7623(b) (i.e., Dec. 20, 2006). Background. Under Code Sec. 7623(a), IRS has […]

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Washington Alert – Bits ‘n Pieces – IRS reacts to decision in Loving; Prop. Reg. re 501(c)(4); Tax Court allows anonymous petitioners in whistleblower cases;

Washington Alert – Bits ‘n Pieces – IRS reacts to decision in Loving; Prop. Reg. re 501(c)(4); Tax Court allows anonymous petitioners in whistleblower cases;

In the wake of a recent court decision, certain tax professionals who were previously suspended or disbarred will now be allowed to obtain or renew preparer tax identification numbers (PTINs) and may again prepare federal tax returns for compensation. (e-News for Tax Professionals 2014-21) According to IRS, the change applies to individuals who were sanctioned […]

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Tax Court dismisses action where IRS declined to pursue whistleblower’s claim

Tax Court dismisses action where IRS declined to pursue whistleblower’s claim

The Tax Court, in Cohen v. Commissioner, 139 T.C. 12 (2012)  has dismissed a CPA’s claim for a whistleblower award based on his allegation that a corporation had unlawfully retained possession of unclaimed proceeds from uncashed dividend checks and unredeemed bonds and failed to report these amounts as income.  The Court said that its jurisdiction […]

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The UBS Whistleblower: An Inside Story

The UBS Whistleblower: An Inside Story

As reported in the news, the IRS gave former UBS banker Bradley Birkenfeld $104 million, the largest amount ever awarded under the tax whistle-blower law.  Here’s what Birkenfeld did to earn it. The $104 million the Internal Revenue Service awarded former UBS banker Bradley Birkenfeld just a little over a month after his release from […]

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IRS Revs up Whistleblower Program, under Senate Pressure

IRS Revs up Whistleblower Program, under Senate Pressure

As reported in the news, apparently the IRS is gearing up the Whistleblower Program under pressure from the Senate.  We have previously blogged on the new Whistleblower Program in “IRS Resists Whistle-Blowers Despite Wide U.S. Tax Gap,” and in “IRS Issues Final Regulations Which Clarify the Computation of Whistleblower Awards.”  Here’s the article. The Internal […]

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IRS Resists Whistle-Blowers Despite Wide U.S. Tax Gap

IRS Resists Whistle-Blowers Despite Wide U.S. Tax Gap

This article on IRS whistleblowers caught my eye, “IRS Resists Whistle-Blowers Despite Wide U.S. Tax Gap, from Bloomberg News.  We previously wrote about the new IRS rules regarding whistleblowers in “IRS Issues Final Regulations Which Clarify the Computation of Whistleblower Awards” and thought the program was heading in the right direction.  Apparently, things are going […]

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IRS Issues Final Regulations Which Clarify the Computation of Whistleblower Awards

IRS Issues Final Regulations Which Clarify the Computation of Whistleblower Awards

IRS has issued Final Regulations in T.D. 9580, 02/21/2012; Reg. § 301.7623-1 , clarifying that, for purposes of calculating and paying the award due to a whistleblower, the terms “amounts collected” and “collected proceeds” include the reduction of an overpayment credit balance used to satisfy a tax liability incurred because of the information provided.  The […]

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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