Insights

“It Depends”—Knowledge and Overpayment Interest Accrual on International Withholding Refund Claims

Federal Court Orders Taxpayer to Repatriate Assets to Satisfy FBAR Penalty Judgment

The Tax Court in Brief November 8 – November 12, 2021

The Build Back Better Act | Tax Implications for Cryptocurrencies

The Foreign Investment in Real Property Tax Act (“FIRPTA”)

The Tax Court in Brief October 25 – October 29, 2021

Fraud Claims Under Texas Law

Illegal Purpose: Breach of Contract Defenses in Texas

Hemphill v. New York: The Confrontation Clause

Settlement Agreements and IRS Forms 1099

The FIRPTA Withholding Obligation

The Defense of Accord and Satisfaction in Texas

The Defense of Unconscionability in Texas

Fraudulent Inducement as a Defense in Texas

Duress as a Defense to Breach of Contract in Texas

Tax Treaties

Competent Authority and Double Taxation

What is the Difference Between Willful and Non-Willful Conduct for FBAR Penalties: The Hughes Decision Provides Some Clarity