Insights

7206(2): The Crime of Aiding or Assisting the Preparation of a False or Fraudulent Document

Types of IRS Audits | The Correspondence Audit

Section 7206(1): False Tax Returns and Statements

U.S. Shareholder: Changes Under the TCJA

The IRS and Big Data: The Future of Fighting Tax Fraud

A Son Bears the Sins of His Father: Bontrager v. Commissioner

Advising International Business Ventures: Tax Reform’s Section 245A Participation Exemption Regime

The Basics of the Trust Fund Recovery Penalty

Innocent Spouse Relief

Second Installment: Advising International Business Ventures: Tax Reform’s “Transition” Tax

Advising International Business Ventures: Tax Reform’s “Transition” Tax

Federal Securities Law – Investment Contracts, the Silent Security

Advising Domestic Business Ventures: Section 199A and Qualified Business Income (“QBI”)

Advising Domestic Business Ventures: A Trade or Business for Purposes of Section 199A

Advising International Business Ventures: Tax Reform’s New GILTI Tax

The Evolving “Yates” Memo | The Department of Justice Revises its Policies on Individual Accountability and Corporate Enforcement

Advising Domestic Business Ventures: Section 199A and Flow-Through Structures

Advising International Business Ventures: Passive Foreign Investment Companies (PFICs)