On April 11, 2019, the IRS announced the results of a national two-week education and enforcement campaign to combat employment tax crimes.  Payroll taxes account for approximately 70% of all revenue collected by the U.S. Treasury.  Given the significance of payroll tax collections to the federal government, IRS revenue officers across the country visited   nearly 100 businesses during the two-week period to discuss suspected employment tax noncompliance by the businesses.  These revenue officers informed the businesses about how to catch-up on previously owed payroll taxes, how to stay current in collecting and remitting payroll taxes, and the potential civil and criminal penalties that businesses and individuals face with respect to noncompliance.

In addition to this educational outreach, IRS Criminal Investigation and the Tax Division of the Justice Department worked together on approximately fifty law enforcement actions related to employment tax crimes.  The two-week campaign resulted in twelve individual indictments, four executed search warrants, and six criminal sentences for individuals and businesses that failed to comply with the employment tax laws.

This campaign demonstrates the seriousness with which the IRS and the Justice Department view employment tax noncompliance and crimes as well as the many tools the IRS has at its disposal to combat noncompliance.  The Justice Department maintains a list of notable employment tax enforcement developments.

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Photo of Molly Ramsden Molly Ramsden

Molly Ramsden’s practice focuses on the design, implementation, and ongoing compliance of employee benefits and executive compensation arrangements.

Molly assists employers of all sizes and industries maneuver the complexities of ERISA, the Internal Revenue Code, and all other federal, state, and local laws…

Molly Ramsden’s practice focuses on the design, implementation, and ongoing compliance of employee benefits and executive compensation arrangements.

Molly assists employers of all sizes and industries maneuver the complexities of ERISA, the Internal Revenue Code, and all other federal, state, and local laws that impact employee benefits and executive compensation.

In particular, Molly frequently advises clients regarding:

  • Health and welfare plans;
  • Tax-qualified retirement plans (defined benefit pension plans, 401(k)s, 403(b)s, etc.)
  • Equity compensation;
  • Nonqualified deferred compensation (top hat plans); and
  • Various other employment and/or benefits related matters.
Photo of Michael M. Lloyd Michael M. Lloyd

Michael Lloyd practices in the areas of tax and employee benefits with a focus on information reporting and withholding on cross-border payments (e.g., Forms 1042 and 1042-S) and Foreign Account Tax Compliance Act (FATCA), backup withholding, employment taxation, the treatment of fringe benefits…

Michael Lloyd practices in the areas of tax and employee benefits with a focus on information reporting and withholding on cross-border payments (e.g., Forms 1042 and 1042-S) and Foreign Account Tax Compliance Act (FATCA), backup withholding, employment taxation, the treatment of fringe benefits, cross-border compensation, domestic information reporting (e.g., Forms W-2, 1099, 1095 series returns), penalty abatement, and general tax planning and controversy matters. Mr. Lloyd advises large U.S. and foreign multinationals regarding compliance with information reporting and withholding issues, as well as a range of other federal and state tax issues.