Whistleblowers Allege DOJ and IRS Mishandled Hunter Biden Case - Cady Stanton, Doug Sword, and Nathan J. Richman, Tax Notes ($):
The House Ways and Means Committee publicly released testimony from two IRS whistleblowers alleging that the Justice Department interfered in an investigation into possible tax crimes by Hunter Biden.
Hundreds of pages of testimony from the two IRS employees — criminal supervisory special agent Gary Shapley and another unnamed whistleblower who worked under Shapley — were released by the committee June 22.
Hunter Biden Didn't Pay Tax On $400K, IRS Agent Says - David van den Berg, Law360 Tax Authority($):
President Joe Biden's son Hunter Biden still hasn't reported about $400,000 in income he received in 2014 from Ukrainian energy company Burisma Holdings Ltd. or paid taxes of about $125,000 on it, according to a transcript released Thursday of a House Ways and Means Committee interview with an IRS agent.
Hunter Biden was told multiple times he needed to amend his 2014 return to report the income, according to Gary Shapley, a supervisory special agent with the Internal Revenue Service's Criminal Investigation division. Shapley was interviewed by the House Ways and Means Committee in May, and the panel released a transcript of it Thursday. Shapley said in the interview that there's no way now to force Hunter Biden to pay the money because the U.S. Department of Justice allowed the statute of limitations to expire.
Whistleblowers say IRS recommended felony charges, allege political interference in Hunter Biden probe - Julia Shapero, The Hill. "Two whistleblowers told a House panel that the Internal Revenue Service (IRS) recommended felony tax charges against Hunter Biden and alleged that there was political interference in the investigation into the president’s son."
House panel releases transcripts from Hunter Biden investigation - Laura Weiss, Roll Call:
The panel made public transcripts totaling almost 400 pages from interviews with two IRS employees, including Criminal Supervisory Special Agent Gary Shapley, who spoke publicly to CBS last month.
Whistleblowers say IRS recommended felony charges, allege political interference in Hunter Biden probe - Julia Shapero, The Hill. "Two whistleblowers told a House panel that the Internal Revenue Service (IRS) recommended felony tax charges against Hunter Biden and alleged that there was political interference in the investigation into the president’s son."
House Panel Tees Up $10.2B IRS Cuts For Full Committee Vote - Asha Glover, Law360 Tax Authority($):
Republicans on a House subcommittee approved a bill Thursday that would rescind $10.2 billion of the IRS' enforcement and operations support funding, clearing the path for the measure to be considered by the full House Appropriations Committee.
Members of the House Appropriations Subcommittee on Financial Services and General Government approved the fiscal year 2024 general government and financial services appropriations bill by voice vote. The bill would claw back $6.1 billion in unobligated funds for enforcement and $4.1 billion for operations support that the Internal Revenue Service received under the Inflation Reduction Act.
IP Repatration Regs Lacked Compelling Reason for Reliance - Andrew Velarde, Tax Notes ($):
The IRS released in May proposed regs (REG-124064-19) that terminate annual income inclusion rules on IP repatriations. Under the rules, section 367(d) is terminated if the transferee foreign corporation repatriates IP to a “qualified domestic person” as long as reporting requirements are met. A partial annual inclusion is still required for the part of the year in which the transferee held the IP.
While some practitioners have expressed gratitude for the proposed regs generally, others have argued that the inability to rely on them may lead some taxpayers to delay their IP repatriation until the regs are finalized.
Litigant Displayed Multiple Badges of Fraud, Says Tax Court - Kristen A. Parillo, Tax Notes ($). "Respondent has demonstrated by clear and convincing evidence that [NAME REDACTED] had fraudulent intent” when he reported fictitious business income and expenses to offset income from a stock sale, Tax Court Judge Cary Douglas Pugh concluded in a June 22 memorandum opinion in [NAME REDACTED] v. Commissioner.
US Seeks $44M In FBAR Fines For Russian Gas Ex-CFO - Anna Scott Farrell, Law360 Tax Authority($):
The U.S. is seeking $43.8 million in civil penalties against a former chief financial officer of Russian gas company Novatek who was convicted of lying to the IRS and hiding money in Swiss banks, according to a complaint filed Thursday in Florida federal court.
Mark Gyetvay owes the penalties, plus interest and late-payment fees, for failing to accurately report two Swiss bank accounts for 2014 — a crime he can no longer argue he didn't commit because a jury convicted him of it in March — the government said in its complaint.
Jury Finds in Favor of Iranian-American Couple in FBAR Case - Andrew Velarde, Tax Notes ($). "A jury has found that the government failed to prove that an Iranian-American couple’s failure to report their Iranian bank accounts was willful."
House Panel Tees Up $10.2B IRS Cuts For Full Committee Vote - Asha Glover, Law360 Tax Authority($):
Republicans on a House subcommittee approved a bill Thursday that would rescind $10.2 billion of the IRS' enforcement and operations support funding, clearing the path for the measure to be considered by the full House Appropriations Committee.
Members of the House Appropriations Subcommittee on Financial Services and General Government approved the fiscal year 2024 general government and financial services appropriations bill by voice vote. The bill would claw back $6.1 billion in unobligated funds for enforcement and $4.1 billion for operations support that the Internal Revenue Service received under the Inflation Reduction Act.
The ‘You-Make-A-Lot-of-Money Tax’ Hits More Americans - Laura Saunders, The Wall Street Journal ($):
Many Americans don’t know Uncle Sam has an extra tax on investment income for higher earners—at least until they owe it. Now more people are owing it, thanks to inflation and higher yields on bank accounts and bonds.
This levy is called the net investment income tax, or NIIT for short. It’s a 3.8% surtax on a filer’s income from sources like interest, dividends and capital gains that applies if adjusted gross income, or AGI, is above $200,000 for most single filers or $250,000 for most married couples. It affects one-time spikes as well as recurring income, so taxpayers who typically earn less can owe it on a windfall.
Today is National Detroit Style Pizza Day. I think you should celebrate with one or all of your favorite styles... New York, Chicago, Detroit, St. Louis, California, or my favorite Quad Cities style.
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