Allegations of COVID-19 pandemic fraud can expose companies and individuals to significant penalties. This includes allegations of fraud under the Paycheck Protection Program (PPP) and Employee Retention Credit (ERC) program. With hundreds of billions of dollars potentially lost to fraud during the pandemic, federal authorities are now working to recoup taxpayers’ losses and hold bad actors accountable.

The Internal Revenue Service (IRS) has announced that it is targeting high-income taxpayers who claim exemptions from federal income tax liability under Puerto Rico Act 60. Not only is the IRS targeting taxpayers for civil enforcement, but it is also pursuing criminal tax evasion charges in some cases.

The Employee Retention Credit (ERC) was one of multiple federal programs that served as a financial lifeline to many businesses during the COVID-19 pandemic. By providing refundable credits to eligible businesses, the ERC helped many businesses stay afloat while also continuing to support their employees.

The Internal Revenue Service (IRS) is cracking down on taxpayers who use Maltese pension plans to avoid federal income tax liability. Signed in 2011, the U.S.-Malta Tax Treaty opened a loophole that allowed (or at least arguably allowed) taxpayers to contribute appreciated assets to Maltese personal retirement plans and then take staggered tax-free distributions.

Submitting fraudulent loan documents to a federally insured bank is a federal crime. This is true regardless of whether the submission results in the issuance of a loan. The federal bank fraud statute (18 U.S.C. Section 1344) is extremely broad, allowing for prosecution of any one who “knowingly executes, or attempts to execute, a scheme or artifice . . . to defraud a financial institution.”