Insights

Third Time’s A Charm: South Dakota v. Wayfair

SEC: Bitcoin and Ether Are Not a Security

Another FBAR Penalty Case Demonstrates the Perils of Failing to Report a Foreign Account

Choice of Entity After Tax Reform

The Colliot Decision: The Government Loses an FBAR Case that May Change International Reporting Penalties

From Worldwide to Territorial, What Does It All Mean?

20/22 Vision – Tax Consequences for Puerto Rico

Understanding Trust Fund Penalty Liability

The Section 965 Transition Tax

The Current Federal Tax Treatment of Cryptocurrency

Tax Reform is Here: A Brief Primer on the Key Business Provisions

Last Call: The IRS Will Soon Close the Offshore Voluntary Disclosure Program, Leaving a Limited Window to Obtain Criminal Amnesty

Bigger Tax Liabilities, Better Installment Agreements

The Taxation of Hard Forks

Your Sins Are Forgiven: The Texas Tax Amnesty Program and Voluntary Disclosure Agreements

Do You Have to Report that Gift to the IRS?

The Limits of the Accountant-Client Privilege

The Paradise Papers Continue to Shed Light on the Use of Offshore Tax Havens