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
The Swiss Bank Program: The Justice Department Announces Final Resolutions
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Jan 13, 2017 Cross-Border Tax Insights, International Tax, Offshore Tax, OVDP
Tax Crimes and the Sentencing Guidelines: Can Unclaimed Tax Deductions Be Considered in Calculating the “Tax Loss”?
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Jan 05, 2017 Criminal, Tax Evasion, White-Collar Defense Insights
The IRS Issues Final Regulations Governing Foreign-Owned Single Member LLCs
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Jan 04, 2017 Cross-Border Tax Insights, International Tax, Offshore Tax
