Insights

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

Coinbase: The Government Strikes Back, Again

The Federal Crime of Failure to File a Tax Return

Bitcoin Forensics – The Facade of Anonymity

The IRS and Captive Insurance Arrangements

Court Finds Senator Rand Paul and Co-Plaintiffs Lacked Standing to Challenge Foreign Account Reporting Rules

The Tax Court Deals a Blow to “Micro-Captive” Insurance Company

The FinCEN Targets Money Laundering in Real Estate Transactions

Enforcement Actions: Virtual Currency Exchanges

Virtual Currency and Taxes: The IRS’s Ongoing Battle to Summons Virtual Currency Records

SEC: Virtual Tokens Issued in Blockchain-Based ICOs may be “Securities”