Foreign-Owned Domestic Disregarded Entities: The New Reporting Requirements
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Apr 27, 2017 Cross-Border Tax Insights, International Tax, IRS Regulations, Offshore Tax
Federal Forfeiture and the Crime of “Structuring”
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Apr 23, 2017 Bank Secrecy Act, Forfeiture, Structuring, White-Collar Defense Insights
Government Report Recommends More Criminal Referrals for Employment Tax Violations
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Apr 19, 2017 Criminal, Employment Tax, Trust Fund Penalty
Department of Justice Issues Warning on the Eve of Tax Deadline: Willful Tax Violators Face Prosecution
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Apr 18, 2017 Criminal, Willfulness
How the FBAR’s “Willfulness” Element Has Recently Evolved
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Apr 07, 2017 Cross-Border Tax Insights, FBAR, White-Collar Defense Insights, Willfulness
The IRS Tax Penalties on the Rise, Particularly Employment Tax Penalties
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Apr 03, 2017 Audit, Employment Tax, Penalties, Trust Fund Penalty
IRS Hits Business Owner with $4.3 Million Trust Fund Penalty for Business’s Unpaid Payroll Taxes—Federal Court Upholds Assessment
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Mar 19, 2017 Employment Tax, Penalties, Trust Fund Penalty
An Update on International Tax Enforcement
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Mar 14, 2017 Audit, Cross-Border Tax Insights, International Tax, Offshore Tax, OVDP, Streamlined Filing
Offshore Tax Evasion Remains on IRS “Dirty Dozen” List for 2017
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Mar 10, 2017 Cross-Border Tax Insights, International Tax, Offshore Tax, OVDP
The Accuracy-Related Penalty and the Reasonable Cause Defense
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Mar 04, 2017 Defenses, Penalties, Tax Litigation Insights
Former University Professor sentenced to Prison for Hiding over $220 Million in Offshore Accounts—Pays $100 Million to Resolve FBAR Penalties
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Feb 24, 2017 Bank Secrecy Act, Cross-Border Tax Insights, FBAR, Fraud, International Tax, Offshore Tax, OVDP, Willfulness
Court Issues Permanent Injunction Against Failing to Pay Employment Taxes
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Feb 20, 2017 Employment Tax, Trust Fund Penalty
A Brief on the New Final Regulations For Shareholders of PFICs
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Feb 06, 2017 Cross-Border Tax Insights, International Tax, Offshore Tax
