By Nathan J. Richman
Tax Notes, August 21, 2017
The Panama Papers and other sources for public leaks are currently being mined for investigatory leads by the IRS and the Justice Department. However, these documents may not be an appropriate cutoff for applying the higher penalty under the IRS's offshore voluntary disclosure program, according to some practitioners in the article authored by Nathan J. Richman.
In a quote from the article:
Jay R. Nanavati of Kostelanetz & Fink LLP said that the list includes individuals and institutions under investigation and not just those who have been convicted or entered into a resolution such as a NPA with the government. Therefore, if the government can satisfy itself on the reliability of the information, "I don't see any good reason not to include institutions that are the subject of leaks like the Panama Papers" in the higher penalty list, he said.
Former Head of DOJ Tax Division and Former Assistant Chief of Criminal Enforcement to Launch New Washington Office
WASHINGTON, D.C. (May 11, 2017) — Kostelanetz & Fink, LLP is pleased to announce that Caroline Ciraolo, former head of the U.S. Department of Justice’s Tax Division, and Jay Nanavati, a former Assistant Chief of the Tax Division’s Criminal Enforcement Section, have joined the firm as partners and founders of the firm’s new Washington, D.C. office.