Insights

Non-US Residents May Still Be Subject to FBAR Reporting Guidelines

The New Partnership Audit Rules: An Expansive Scope and Penalty Defenses

The Badges of Fraud

Why (Nearly) Every Partnership Agreement Should be Amended?

Suspected Currency Structuring Leads to Enhanced Sentence for Tax Fraud

Foreign-Owned Domestic Disregarded Entities: The New Reporting Requirements

Federal Forfeiture and the Crime of “Structuring”

Government Report Recommends More Criminal Referrals for Employment Tax Violations

Department of Justice Issues Warning on the Eve of Tax Deadline: Willful Tax Violators Face Prosecution

Federal Asset Forfeiture

How the FBAR’s “Willfulness” Element Has Recently Evolved

The IRS Tax Penalties on the Rise, Particularly Employment Tax Penalties

IRS Hits Business Owner with $4.3 Million Trust Fund Penalty for Business’s Unpaid Payroll Taxes—Federal Court Upholds Assessment

An Update on International Tax Enforcement

Offshore Tax Evasion Remains on IRS “Dirty Dozen” List for 2017

The Accuracy-Related Penalty and the Reasonable Cause Defense

Former University Professor sentenced to Prison for Hiding over $220 Million in Offshore Accounts—Pays $100 Million to Resolve FBAR Penalties

Court Issues Permanent Injunction Against Failing to Pay Employment Taxes