Money Laundering, Structuring, and Other Federal Tax Crimes

Includes a Live Event on 09/30/2020 at 11:00 AM (EDT)

Money Laundering is an action taken to conceal the origin of illegally obtained money.  We will be discussing a key element in a money laundering charge, which requires the government to establish that the assets in question are linked to a specified unlawful activity (SUA).  SUA is a legal term that refers to a statutory list of crimes, and proceeds derived from crimes not on that list cannot be laundered.  A money laundering charge in an indictment can drastically inflate the government’s ability to forfeit a defendant’s assets.  We will discuss why it is crucial to know when a case involves money laundering and when it does not. Structuring is a term used to describe a violation of 31 U.S.C. §5324, which prohibits the act of evading reporting requirements.  31 U.S.C. §5324(a), the most commonly violated section of the statute, deals with transactions involving financial institutions.  We will review how this section is split into three subparts, each of which defines a different type of structuring charge.  The IRS and DOJ have been using the structuring statute as a means for obtaining civil and criminal asset forfeitures, We will be reviewing the differences between the subparts – specifically between §5324(a)(1) and §5324(a)(3).  We will also be discussing the scrutiny that assets forfeitures based on structuring violations have been receiving, and the recent DOJ and IRS policy changes.

Money Laundering is an action taken to conceal the origin of illegally obtained money.  We will be discussing a key element in a money laundering charge, which requires the government to establish that the assets in question are linked to a specified unlawful activity (SUA).  SUA is a legal term that refers to a statutory list of crimes, and proceeds derived from crimes not on that list cannot be laundered.  A money laundering charge in an indictment can drastically inflate the government’s ability to forfeit a defendant’s assets.  We will discuss why it is crucial to know when a case involves money laundering and when it does not. Structuring is a term used to describe a violation of 31 U.S.C. §5324, which prohibits the act of evading reporting requirements.  31 U.S.C. §5324(a), the most commonly violated section of the statute, deals with transactions involving financial institutions.  We will review how this section is split into three subparts, each of which defines a different type of structuring charge.  The IRS and DOJ have been using the structuring statute as a means for obtaining civil and criminal asset forfeitures, We will be reviewing the differences between the subparts – specifically between §5324(a)(1) and §5324(a)(3).  We will also be discussing the scrutiny that assets forfeitures based on structuring violations have been receiving, and the recent DOJ and IRS policy changes.


IRS CE: 1 Hours/Federal Tax Law Update
NASBA CE: 1 Hours/Federal Tax Law Update
CTEC CE: 1 Hours/Federal Tax Law Update

NSA ConnectED Webinar CPE Bonanza 
Program Level: Basic
Prerequisites: None 
Advance Preparation: None 
Delivery Method: Group-Internet Based

No refunds or exchanges for cancellations. For more information regarding refund, complaint and/or program cancellation policies, please contact NSA toll-free at 800-966-6679.

NSA is approced by NASBA, the IRS, ACAT, and CTEC as a provider of continuing professional education.

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Randy Andreozzi

Mr. Andreozzi’s legal career has focused on resolution of complex tax controversy matters, large case (corporate) tax matters, tax shelter litigation, employee welfare benefit litigation, and international/territorial tax issues.

For 16 years, Mr. Andreozzi worked for the IRS Office of Chief Counsel, where he served as Industry Counsel for the Commissioner’s Industry Specialization Program (ISP). He evaluated and litigated tax cases presenting Welfare Benefit Plan issues. Mr. Andreozzi litigated many seminal cases in this area, including General Signal Corp. v. Commissioner, Booth v. Commissioner, Parker Hannifin Corporation v. Commissioner, Square D Co. v. Commissioner and Neonatology Associates v. Commissioner. He also assisted and counseled other IRS attorneys and revenue agents in their development of cases under the ISP program, offering valuable expertise in areas involving tax shelters and the corporate income tax consequences of VEBAs and Welfare Benefit Plans.

During his years with the IRS Chief Counsel’s office, Mr. Andreozzi cultivated a strong reputation with attorneys and agents throughout IRS, as well as with outside tax practitioners nationwide. His extensive trial experience extends to other complex tax areas as well. Mr. Andreozzi tried a variety of complex precedential cases that have established important precedent in the areas of abusive tax shelters, corporate acquisitions (INDOPCO v. Commissioner), international taxation, United States Virgin Islands territorial taxation, and TEFRA partnerships.

Now in private practice with the firm of Andreozzi Bluestein LLP, Mr. Andreozzi continues to focus his practice on complex tax litigation and tax controversy resolution. His practice areas include international taxation and foreign bank account reporting, criminal tax and financial crime defense, employee benefit taxation, tax shelter litigation, and a variety emerging areas of federal and state tax law.

Mr. Andreozzi has published numerous articles on taxation, and frequently lectures on a variety of current and developing tax issues. He is an Adjunct Professor at the State University of New York (SUNY) at Buffalo School of Management, where he teaches Business Law at both the graduate and undergraduate levels. While he was with the IRS Office of Chief Counsel, he trained Chief Counsel trial attorneys at national litigation schools.

 

Justin Andreozzi

Justin is a Senior Associate at Andreozzi Bluestein LLP.  He received his B.A. from Roberts Wesleyan College in Rochester, New York, and he received his J.D. from the State University of New York at Buffalo Law School.  Justin concentrated in tax at SUNY Buffalo Law School, taking courses including Federal Income Tax I & II, Tax Policy, State & Local Taxation, Corporate Taxation, and a tax focused independent study. His practice is focused on individual and corporate tax controversy and criminal litigation.

Along with his commitment to the firm, Justin has also shown a commitment to assisting low income individuals in Buffalo. His concerted efforts with other attorneys at Andreozzi Bluestein LLP were recognized when our firm received the Law Firm Commitment Award from the ECBA Volunteer Lawyers Project in 2014.  Justin was also honored as a selection in Buffalo Business First’s 2016 “30 Under 30.”


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