Insights

IRS Form 3520 – Reporting Transactions with Foreign Trusts and the Receipt of Foreign Gifts

The Crossroads of Civil Litigation and Federal Tax Matters: A Primer for Plaintiff’s Attorneys

Recent Decision Emphasizes Importance of Maintaining Adequate Business Records

Leaders of CFTC, FinCEN, and SEC Issue Joint Statement on Digital Assets

The Defend Trade Secrets Act

IRS Form 5472

Tax Court Clarifies Burden of Production in Section 6751(b) Cases

IRS Form 5471 – Information Return of U.S. Persons With Respect to Certain Foreign Corporations

The IRS Whistleblower Program

“Hot Assets” and the Sale or Exchange of Partnership Interests

International Reporting Penalties

The IRS Increasing Enforcement of Syndicated Conservation Easements

The New “Wayfair” Sales Tax Laws in Texas

Where Is the Limit on Penalties for Willful FBAR Violations?

The Sham Trust Doctrine – When will a Court Disregard a Trust for Federal Tax Purposes?

The Recent FBAR Case Allows Multiple Penalties for Single Failure to File FBAR

International Tax Enforcement: The Joint Chiefs of Global Tax Enforcement

Innocent Spouse Relief: A Primer