Insights

Foreign Bank Account Reporting | The FBAR

Litigating IRS Penalties

The 10 Most Litigated Tax Issues of 2015

The First Lawsuit Challenging the IRS’s New Anti-Inversion Regulations

No Soup for You | District Court Finds Restaurant Owners Personally Liable for Trust Fund Taxes and Imposes an Injunction Against Failure to Comply with Future Tax Obligations

Partnership Foreign Tax Withholding Obligations

The Cheek Defense to Federal Tax Crimes

The Latest IRS Tax Identity Theft Scheme

The Brazilian Tax Amnesty Program: The Regime Especial de Regularização Cambial e Tributária

Expatriate Group Urges Adoption of a Same-Country FATCA Reporting Exception

Facebook Under IRS Audit: Facing IRS Transfer Pricing Challenges, Facebook Refuses to Comply with Summonses

Government Report Finds that Improvements are Needed in the Offshore Voluntary Disclosure Program

The Tax Court Upholds Tax Fraud Assessment Against Incarcerated Former IRS Examiner and Disbarred Attorney

The Form 8300 Filing Requirement and Associated Penalties

EXPATRIATION | ULTIMATE OPT OUT? HASSLE? BOTH?

Panama to Join OECD’s Convention on Mutual Administrative Assistance in Tax Matters in Wake of Panama Papers Leak

A Brave New World | The Panama Papers and the United States’ Role as a Tax Haven

TIGTA Report Critical of the Offshore Voluntary Disclosure Program, Finds that the IRS Should Assess More FBAR Penalties