Insights

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

A Battle of the Dakotas: South Dakota v. Wayfair

Fines and Penalties and Payments, Oh My! — The New Section 162(f)

What is Bank Fraud?

What is “Economic Substance?”

Charges of Conspiracy: A Potential Consequence of the Supreme Court’s Recent Decision in Marinello

Initial Coin Offerings (“ICO”) Regulation

The ACA’s Employer Shared Responsibility Provisions FAQs

Cryptocurrency Regulation: Recent Developments

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