Insights

Affordable Care Act: Employer Penalties

Not So Fast, IRS…My Client Wasn’t Aware: Marinello v. United States

Cryptocurrency | The IRS’s Next Big Crackdown

Last Call: The Offshore Voluntary Disclosure Program to End

IRS Summonses Against Attorneys-What Can the IRS Compel You to Disclose?

2018 Tax Reform: What You Need to Know Now

Bitcoin, Blockchain, and the Revolution to Come

Held Captive: Micro-Captive Insurance in the Aftermath of Avrahami

A Primer on the Tax Implications of Settlements and Judgments

The Computer Fraud and Abuse Act (CFAA)

Computer Crimes

Taxes and Bankruptcy: IRS-Prepared Substitute Returns

IRS Penalties — A Brief Primer

IRS Required to Return FBAR “Penalty:” Penalty was “Illegally Exacted”

Determining the Enforceability of a Section 6038A Summons

The Crime of Tax Evasion

Is “Form” “Substance” When it Comes to Law? The Future of the Doctrines of Economic Substance and Substance Over Form

Summoning Foreign Records: The Section 6038A Summons