Insights

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

By Jason B. Freeman Jul 21, 2019 Economic Substance, Sham Trust, Trust

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

By Jason B. Freeman Jul 16, 2019 Cross-Border Tax Insights, FBAR, International Tax

International Tax Enforcement: The Joint Chiefs of Global Tax Enforcement

By Jason B. Freeman Jun 10, 2019 Cross-Border Tax Insights, International Tax, Tax Evasion, White-Collar Defense Insights

Innocent Spouse Relief: A Primer

By Jason B. Freeman Apr 07, 2019 Innocent Spouse Relief

Doing Business With the IRS

By Freeman Law Mar 21, 2019 Penalties

A Fresh Start for Taxpayers: The Offer in Compromise

By Jason B. Freeman Mar 17, 2019 Offer in Compromise

The IRS Office Audit

By Freeman Law Mar 14, 2019 Audit, Tax Litigation Insights

Tax Preparers and Criminal Exposure: Be Careful Out There!

By Jason B. Freeman Mar 11, 2019 Criminal, Fraud, White-Collar Defense Insights

Advising International Business Ventures: “Tested Income” under GILTI

By Jason B. Freeman Mar 07, 2019 Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, GILTI, International Tax, Tax Reform

7206(2): The Crime of Aiding or Assisting the Preparation of a False or Fraudulent Document

By Jason B. Freeman Mar 04, 2019 Criminal, Evasion, Fraud, White-Collar Defense Insights

Types of IRS Audits | The Correspondence Audit

By Freeman Law Feb 28, 2019 Audit

Section 7206(1): False Tax Returns and Statements

By Jason B. Freeman Feb 24, 2019 Criminal, Evasion, Fraud, White-Collar Defense Insights

U.S. Shareholder: Changes Under the TCJA

By Jason B. Freeman Feb 21, 2019 Controlled Foreign Corporation (CFC), Corporate, Cross-Border Tax Insights, International Tax, Tax Reform

The IRS and Big Data: The Future of Fighting Tax Fraud

By Jason B. Freeman Feb 18, 2019 Data Analytics, Tax Fraud

A Son Bears the Sins of His Father: Bontrager v. Commissioner

By Freeman Law Feb 14, 2019 Criminal, Restitution, Tax Court, Tax Evasion, White-Collar Defense Insights

Advising International Business Ventures: Tax Reform’s Section 245A Participation Exemption Regime

By Jason B. Freeman Feb 11, 2019 Cross-Border Tax Insights, International Tax, Tax Reform

The Basics of the Trust Fund Recovery Penalty

By Freeman Law Feb 07, 2019 Trust Fund Penalty

Innocent Spouse Relief

By Freeman Law Feb 02, 2019 Innocent Spouse Relief