Where Is the Limit on Penalties for Willful FBAR Violations?
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Dec 23, 2019 Bank Fraud, Cross-Border Tax Insights, Evasion, FBAR, Fines, Fraud, International Tax
The Sham Trust Doctrine – When will a Court Disregard a Trust for Federal Tax Purposes?
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Jul 21, 2019 Economic Substance, Sham Trust, Trust
The Recent FBAR Case Allows Multiple Penalties for Single Failure to File FBAR
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Jul 16, 2019 Cross-Border Tax Insights, FBAR, International Tax
International Tax Enforcement: The Joint Chiefs of Global Tax Enforcement
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Jun 10, 2019 Cross-Border Tax Insights, International Tax, Tax Evasion, White-Collar Defense Insights
Tax Preparers and Criminal Exposure: Be Careful Out There!
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Mar 11, 2019 Criminal, Fraud, White-Collar Defense Insights
Advising International Business Ventures: “Tested Income” under GILTI
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Mar 07, 2019 Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, GILTI, International Tax, Tax Reform
7206(2): The Crime of Aiding or Assisting the Preparation of a False or Fraudulent Document
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Mar 04, 2019 Criminal, Evasion, Fraud, White-Collar Defense Insights
Section 7206(1): False Tax Returns and Statements
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Feb 24, 2019 Criminal, Evasion, Fraud, White-Collar Defense Insights
U.S. Shareholder: Changes Under the TCJA
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Feb 21, 2019 Controlled Foreign Corporation (CFC), Corporate, Cross-Border Tax Insights, International Tax, Tax Reform
A Son Bears the Sins of His Father: Bontrager v. Commissioner
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Feb 14, 2019 Criminal, Restitution, Tax Court, Tax Evasion, White-Collar Defense Insights
