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Insights into the different ways tribal entities can be structured and the tax implications of each; what constitutes a federally recognized tribe and the benefits of such; and the taxability of certain types of income to tribal members.

Residency, withholding and federal income tax filing requirements for individuals in the U.S. on an H-1B visa.

Residency, withholding and federal income tax filing requirements for individuals in the U.S. on a J-1 visa.

Jan. 11, 2024 — William Koo Ichioka was sentenced to serve four years in prison and ordered to pay a $5 million fine for committing multiple felonies in connection with an investment fraud scheme involving cryptocurrencies and other investment vehicles. The sentence was handed down by the Hon. Vince Chhabria, United States District Judge.

Legal advice signed by executives in the National Office of the Office of Chief Counsel and issued to Internal Revenue Service personnel who are national program executives and managers.

August 23, 2023 — The unsealing of an Indictment was announced today, charging Roman Storm and Roman Semenov with conspiracy to commit money laundering, conspiracy to commit sanctions violations, and conspiracy to operate an unlicensed money transmitting business. The charges in the Indictment arise from the defendants' alleged creation, operation, and promotion of Tornado Cash, a cryptocurrency mixer that facilitated more than $1 billion in money laundering transactions and laundered hundreds of millions of dollars for the Lazarus Group, the sanctioned North Korean cybercrime organization. Roman Storm was arrested today in the state of Washington and will be presented today in the U.S. District Court for the Western District of Washington. The case has been assigned to U.S. District Judge Katherine Polk Failla. Semenov remains at large.

June 22, 2023 — Today, the United States announced the filing of an information charging William Koo Ichioka with multiple felonies in connection with “Ichioka Ventures,” an alleged investment fraud scheme involving cryptocurrencies and other investment vehicles. According to court documents filed in the case, Ichioka has agreed to plead guilty to charges of wire fraud, aiding or assisting in the preparation of a false or fraudulent tax return, fraud in connection with the purchase and sale of securities, and commodities fraud.

August 9, 2022 — Charges unsealed today against four individuals, including two San Diego residents, allege that they defrauded a multinational San Diego technology company in its $150 million purchase of a tech start-up controlled by the defendants.

Links to research papers alphabetized by Author

"The Truth About Frivolous Tax Arguments" addresses frivolous tax arguments in general. This document was updated March 2022.