Laura L. Gavioli, PC Laura L. Gavioli, PC

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Laura L. Gavioli, PC, defends individuals and corporations in white-collar prosecutions, civil tax cases, US Internal Revenue Service (IRS) controversies and complex financial litigation. Laura represents numerous taxpayers who are facing civil and criminal issues regarding their reporting of offshore financial accounts and other assets. Laura has also represented clients involved in some of the largest white-collar criminal tax evasion cases ever brought in the United States, and she regularly advises clients regarding the IRS Whistleblower Program. Read Laura Gavioli's full bio.

When the IRS Says It’ll ‘Meet You in Paris’: Recent Trends & Developments in Outbound US Exchange-of-Information Techniques


By on Oct 3, 2019
Posted In IRS Guidance, Uncategorized

The Internal Revenue Service is looking for your international tax data—that is, if the IRS doesn’t already have it. With the rollout of the Foreign Account Tax Compliance Act (FATCA) and other automatic exchange-of-information (EOI) procedures, the IRS is now receiving—and making use of—a large amount of international tax information about US taxpayers. In an...

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Watch Your Mailbox: IRS Letters Warning of Cryptocurrency Non-Compliance on Their Way


By on Jul 30, 2019
Posted In IRS Guidance, Uncategorized

On July 26, 2019, the Internal Revenue Service (IRS) issued a press release informing the public that it is sending more than 10,000 letters to taxpayers with potentially unreported (or misreported) virtual currency transactions. The letters will inform them of the possible reporting requirements that may apply to these transactions and advise them of the...

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Law360: Myers May Make It Easier to Find Equitable Relief in Tax Court


By on Jul 18, 2019
Posted In Appellate Courts, Court Procedure Matters, Trial Courts, Uncategorized

Laura L. Gavioli, PC, recently wrote an article for Law360 on a US Court of Appeals for the District of Columbia Circuit’s decision that may provide an equitable avenue for hearing of late-filed petitions in US Tax Court. The Law360 article, “Myers May Make It Easier to Find Equitable Relief in Tax Court,” can be...

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Is an Increase in LB&I Assertion of Penalties on the Horizon?


By on Jun 5, 2019
Posted In IRS Appeals, IRS Audits, IRS Guidance, Uncategorized

On May 31, 2019, the Treasury Inspector General for Tax Administration (TIGTA) released a report indicating that changes may be in the works regarding assertion of accuracy-related penalties in examinations handled by the IRS Large Business & International (LB&I) Division. The TIGTA report reviewed the results of closed LB&I examinations for the fiscal years 2015...

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IRS LB&I Sharpens Its Risk Analysis, Announces Large Corporate Compliance (LCC) Program


By on May 24, 2019
Posted In IRS Audits, IRS Guidance, Uncategorized

Last week, the IRS unveiled a major change in how it identifies its biggest and most complex large corporations for examination. The move is part of the IRS’s broader efforts toward “portfolio management”—maximizing and modernizing its resources to focus upon areas of highest tax compliance risk. The IRS’s Large Business and International Division (LB&I) has...

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Reasonable Cause for E-Filing Errors?


By and on Mar 7, 2019
Posted In Court Procedure Matters, IRS Guidance, Tax Reform, Uncategorized

Tax return filing season is fast approaching, and taxpayers big and small are preparing to file their returns. A recent US Court of Appeals for the Fifth Circuit decision, Haynes v. United States, No. 17-50816 (5th Cir. Jan. 29, 2019), indicates that many of those taxpayers will face uncertainty if their returns are late due...

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Cryptocurrency May Be Subject to US Tax: Come Into Compliance Now


By , and on Nov 16, 2018
Posted In IRS Guidance, Uncategorized

Lately, we have been frequently asked the question: “I file US tax returns and pay taxes here. Are my cryptocurrency transactions taxable or reportable in the US?” The answer for US persons and US taxpayers most likely is “yes.” US persons are generally taxable on income earned worldwide, regardless of the manner in which that...

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Kovel Protections Upheld | Government Loses Aggressive Arguments for Waiver of Privilege for Controversy Advice


By on Nov 12, 2018
Posted In Court Procedure Matters, IRS Guidance, Privilege and Non-Disclosure, Trial Courts, Uncategorized

On October 27, the US District Court for the District of Minnesota issued an opinion in United States v. Adams, No. 0:17-cr-00064-DWF-KMM (D. Minn. Oct. 27, 2018), addressing attorney-client privilege issues relevant to accountants working alongside tax attorneys. The court adopted a narrow, nuanced view of the waiver that applies when the taxpayer discloses an...

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OVDP Ending September 28: Now Is the Time to Disclose


By on Aug 23, 2018
Posted In IRS Audits, IRS Guidance, Privilege and Non-Disclosure, Uncategorized

Earlier this year, the Internal Revenue Service (IRS) announced the ending of the 2014 Offshore Voluntary Disclosure Program (OVDP), its formal amnesty program for taxpayers with previously undisclosed interests in foreign assets and financial accounts. The program deadline is September 28, 2018, and all submissions must be substantially completed by that deadline. Partial or “placeholder”...

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IRS OVDP Ending | Time Is Now for Coming into US Tax Compliance – Especially for Those with Willfulness Issues


By , and on Mar 16, 2018
Posted In Alternative Dispute Resolution, IRS Audits, IRS Guidance, Settlements, Uncategorized

On March 13, 2018, the Internal Revenue Service (IRS) announced that it will begin ramping down the current Offshore Voluntary Disclosure Program (OVDP) and urged taxpayers with undisclosed foreign assets to apply for the program prior to its close on September 28, 2018. We have previously reported on developments in the OVDP. Access the full article. 

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