Insights

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)

Tax Crimes: Section 7203 and Willful Failures to File a Tax Return

Advising International Business Ventures: Controlled Foreign Corporations and Subpart F

Advising International Business Ventures: Tax Reform and a Quasi-Territorial Tax System

The Willful FBAR Penalty: Bedrosian and New Insights

Innocent Spouse Relief

Tax-Related Passport Restrictions and IRS Notices of Seriously Delinquent Federal Tax Debts

1099-K Audits

Tolling of the Tax Lookback Period for Discharge of Tax Debt in Bankruptcy

I.R.C. § 7212 | Interfering with the Administration of Tax Laws

The IRS’s Bank Secrecy Act Program Has Minimal Impact on Compliance

Tax Evasion: Evading the Payment of Tax

The Willful Failure to Collect or Pay over Tax