Federal Forfeiture and the Crime of “Structuring”
By
Apr 23, 2017 Bank Secrecy Act, Forfeiture, Structuring, White-Collar Defense Insights
Government Report Recommends More Criminal Referrals for Employment Tax Violations
By
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
By
Apr 18, 2017 Criminal, Willfulness
How the FBAR’s “Willfulness” Element Has Recently Evolved
By
Apr 07, 2017 Cross-Border Tax Insights, FBAR, White-Collar Defense Insights, Willfulness
The IRS Tax Penalties on the Rise, Particularly Employment Tax Penalties
By
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
By
Mar 19, 2017 Employment Tax, Penalties, Trust Fund Penalty
An Update on International Tax Enforcement
By
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
By
Mar 10, 2017 Cross-Border Tax Insights, International Tax, Offshore Tax, OVDP
The Accuracy-Related Penalty and the Reasonable Cause Defense
By
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
By
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
By
Feb 20, 2017 Employment Tax, Trust Fund Penalty
A Brief on the New Final Regulations For Shareholders of PFICs
By
Feb 06, 2017 Cross-Border Tax Insights, International Tax, Offshore Tax
The Swiss Bank Program: The Justice Department Announces Final Resolutions
By
Jan 13, 2017 Cross-Border Tax Insights, International Tax, Offshore Tax, OVDP
