Why Taxpayers in Louisiana, Texas, and Mississippi Should Consider the IRS’s Streamlined Compliance Procedure Program Now

The Tax Risk of a Permanent Establishment

Tax Controversies After BEPS

Beware of Your FBAR Obligations | U.S. v. Solomon

“It Depends”—Knowledge and Overpayment Interest Accrual on International Withholding Refund Claims

Federal Court Orders Taxpayer to Repatriate Assets to Satisfy FBAR Penalty Judgment

The Foreign Investment in Real Property Tax Act (“FIRPTA”)

The FIRPTA Withholding Obligation

Tax Treaties

Competent Authority and Double Taxation

What is the Difference Between Willful and Non-Willful Conduct for FBAR Penalties: The Hughes Decision Provides Some Clarity

Form 8938 and FinCEN Form 114 Compared

Global Tax Agreement May Shake Up Taxation of Multinational Enterprises

Defenses to Section 6038 IRS Penalties

The Section 965 Transition Tax And IRS Audits

Failure to Report Foreign Trust

Do FBAR Penalties Survive Death? A Texas Court Says “Yes”

IRS Gets Green Light to Seek Information from Third Parties Regarding Panama Offshore Legal Services