Carlos Ortiz

Get Ready For IRS Criminal Crackdown On Crypto

By Carlos Ortiz, Christina Gotsis and Kayley Sullivan on May 3, 2023 Posted in Cryptocurrency

Carlos Ortiz, Christina Gotsis and Kayley Sullivan co-authored the article “Get Ready For IRS Criminal Crackdown On Crypto,” in Law360. After years of warnings, the time for a significant increase in IRS criminal enforcement against those using digital assets to evade tax liabilities is here. The 2022 IRS Criminal Investigation annual report, and the agency’s … Continue Reading

DOJ Seizes Over $3 Billion in Historic Crypto Dark Web Fraud Case

By Teresa Goody Guillén, Carlos Ortiz, Shade Quailey and Michelle Tanney on November 21, 2022 Posted in Cryptocurrency

On November 7, 2022, the U.S. Department of Justice (DOJ) announced that it had seized more than $3.36 billion worth of bitcoin as part of a continuing investigation into a 10-year fraud involving the Silk Road dark web marketplace. This seizure signifies the DOJ’s second-largest cryptocurrency seizure and financial seizure in history, and it demonstrates … Continue Reading

IRS Warns: Hundreds of Crypto Criminal Tax Cases Coming Soon; Hiring of 300 Special Agents Means More to Follow

By Scott Danielson, Christina Gotsis, Carlos Ortiz, Veronica Reynolds, Betsy Smith and Kayley Sullivan on November 16, 2022 Posted in Alert

The 2022 annual report from the IRS Criminal Investigations (CI) division (the Report) demonstrates an impressive year for enforcement, particularly with regard to cryptocurrency. Following the publication, CI Chief Jim Lee made clear that the division will continue to closely scrutinize crypto transactions. He warned: “Expect more outward-facing tax crypto cases here in the near … Continue Reading

The Tax Man Isn’t Leaving: The IRS Continues to Issue John Doe Summonses Relating to Virtual Currency Transactions

By Carlos Ortiz, Betsy Smith, Nicholas C. Mowbray, Christina Gotsis and Kayley Sullivan on October 3, 2022 Posted in Tax

On Sept. 23, 2022, a U.S. District Court judge approved an IRS John Doe summons served on a New York-based bank seeking account records, including account opening documents and records of deposits, withdrawals, transfers and wires, of clients who used sFOX for cryptocurrency services. The summons was issued in connection with partnered services the bank … Continue Reading

The Tax Man Is Back: IRS Issues First John Doe Summons in 2022 to Major Crypto Platform, Seeking Treasure Trove of Information on Tax Noncompliance

By Carlos Ortiz, Nicholas C. Mowbray, Christina Gotsis and Kayley Sullivan on August 22, 2022 Posted in Cryptocurrency, Tax

After going for more than a year without using one of its most powerful weapons, a John Doe summons, the Internal Revenue Service (IRS) has reverted to the use of this tool in its much-publicized efforts to investigate, find, and prosecute those who fail to report virtual currency transactions and those who facilitate not reporting. … Continue Reading

DOJ Calls on International Partners to Improve Investigative Efficiency in Response to President Biden’s Executive Order on Risks Involving Digital Assets

By Carlos Ortiz, Robert A. Musiala, Teresa Goody Guillén, John J. Carney, Christina Gotsis, Veronica Reynolds and Kayley Sullivan on June 30, 2022 Posted in Blockchain

In June 2022, the Department of Justice (DOJ) issued a report (Report) recommending increased cooperation among international law enforcement agencies to combat threats and crime related to the use and proliferation of digital assets and to address obstacles unique to the asset class. Specific actions recommended by the Report include expanding U.S. relationships with international … Continue Reading

Cryptocurrency Tax Enforcement May Soon Reward Tipsters Through Whistleblower Program and False Claims Act

By Carlos Ortiz, Nicholas C. Mowbray, Betsy Smith, Christina Gotsis and Kayley Sullivan on May 24, 2022 Posted in Blockchain

International and state authorities could soon bolster enforcement efforts by rewarding individuals who provide information about underreporting income on virtual currency transactions. As a result, digital asset investors and their tax advisors could find themselves subject to liability under yet another regulation creeping into cryptocurrency governance. Taxpayers who skirt tax payments on virtual investments could … Continue Reading

Global Tax Enforcement Group Provides NFT Red Flag Guidance

By Teresa Goody Guillén, Christina Gotsis, Nicholas C. Mowbray, Betsy Smith and Carlos Ortiz on May 3, 2022 Posted in NFT

Answering the call for guidance regarding potential issues concerning the popular cryptocurrency assets NFTs, on April 28, the J5 issued a first-of-its-kind intelligence bulletin warning the public of the dangers of dealing with NFTs. Titled the “J5 NFT Marketplace Red Flag Indicators,” the bulletin provides real-world guidance to banks, law enforcement partners and private investigators … Continue Reading