International Tax Enforcement: The Joint Chiefs of Global Tax Enforcement

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Jason B. Freeman

Jason B. Freeman

Managing Member

214.984.3410
Jason@FreemanLaw.com

Mr. Freeman is the founding member of Freeman Law, PLLC. He is a dual-credentialed attorney-CPA, author, law professor, and trial attorney.

Mr. Freeman has been named by Chambers & Partners as among the leading tax and litigation attorneys in the United States and to U.S. News and World Report’s Best Lawyers in America list. He is a former recipient of the American Bar Association’s “On the Rise – Top 40 Young Lawyers” in America award. Mr. Freeman was named the “Leading Tax Controversy Litigation Attorney of the Year” for the State of Texas for 2019 and 2020 by AI.

Mr. Freeman has been recognized multiple times by D Magazine, a D Magazine Partner service, as one of the Best Lawyers in Dallas, and as a Super Lawyer by Super Lawyers, a Thomson Reuters service. He has previously been recognized by Super Lawyers as a Top 100 Up-And-Coming Attorney in Texas.

Mr. Freeman currently serves as the chairman of the Texas Society of CPAs (TXCPA). He is a former chairman of the Dallas Society of CPAs (TXCPA-Dallas). Mr. Freeman also served multiple terms as the President of the North Texas chapter of the American Academy of Attorney-CPAs. He has been previously recognized as the Young CPA of the Year in the State of Texas (an award given to only one CPA in the state of Texas under 40).

Earlier this year, the IRS launched and joined the Joint Chiefs of Global Tax Enforcement, known as the “J5,” in an effort to crack down on international tax fraud, money laundering, and cryptocurrency-related crimes. The J5 includes agencies from the United Kingdom, Canada, Australia, and the Netherlands, along with the IRS. The initiative involves a stated effort to share information and conduct joint investigations in order to “reduce the growing threat posed to tax administrations by cryptocurrencies and cybercrime.”
The J5 was formed in response to the Organization for Economic Co-Operation and Development’s (OECD) request for an international effort to curb tax crimes. The J5’s mission statement provides that it was formed “in response to the OECD’s call for countries to do more to tackle the enablers of tax crime.”  The J5 is somewhat similar to the Joint International Tax-Sheltered Information and Collaboration (JITSIC), which was established by 38 countries and is open to all members of the OECD’s forum on tax administration (FTA).

The IRS previously elaborated on the perceived need for the new effort, clearly identifying its belief that offshore structures and cryptocurrencies pose a significant threat to tax administration:

We are convinced that offshore structures and financial instruments, where used to commit tax crime and money laundering, are detrimental to the economic, fiscal, and social interests of our countries. We will work together to investigate those who enable transnational tax crime and money laundering and those who benefit from it. We will also collaborate internationally to reduce the growing threat to tax administrations posed by cryptocurrencies and cybercrime and to make the most of data and technology.

See the release here.

According to Don Fort, Chief of IRS-CI, the IRS, “cannot continue to operate in the same ways we have in the past, siloing our information from the rest of the world while organized criminals and tax cheats manipulate the system and exploit vulnerabilities for their personal gain. The J5 aims to break down those walls, build on individual best practices, and become an operational group that is forward-thinking and can pressurize the global criminal community in ways we could not achieve on our own.”

Notably, the IRS entered the new initiative as it wound down its Offshore Voluntary Disclosure Program, as well as its Swiss Bank Program.  It is an outgrowth of those efforts, and is designed to build upon the enormous amounts of data that countries such as the United States have obtained over the past decade.  Notably, the J5 initiative underscores a new focus on cryptocurrency-related tax evasion.  It also indicates that the IRS and other tax enforcement agencies across the globe are likely to utilize the lessons learned in recent years in the battle to curb international tax evasion.

All signs indicate that the IRS will continue to very aggressively pursue offshore accounts as it pushes forward into a new era of information sharing. Those signs are reinforced by a number of recent prosecutions, including of a former bank executive for failing to comply with the Foreign Account tax Compliance Act (release here), a California man who failed to report funds held in an Israeli offshore account (release here), and a taxpayer who made false representations during an IRS audit that ultimately uncovered an unreported account (release here).  Expect to see more prosecutions in the months ahead related to claims of international tax evasion.

Expert Tax Defense Attorneys

Need help with tax issues? Contact us as soon as possible to discuss your rights and the ways we can assist in your defenseWe handle all types of cases, including complex international & offshore tax compliance. Schedule a Consultation or call (214) 984-3000 to discuss your international tax concerns or questions.