The Colliot Decision: The Government Loses an FBAR Case that May Change International Reporting Penalties

From Worldwide to Territorial, What Does It All Mean?

20/22 Vision – Tax Consequences for Puerto Rico

The Section 965 Transition Tax

The Paradise Papers Continue to Shed Light on the Use of Offshore Tax Havens

Last Call: The Offshore Voluntary Disclosure Program to End

Determining the Enforceability of a Section 6038A Summons

Summoning Foreign Records: The Section 6038A Summons

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

Non-US Residents May Still Be Subject to FBAR Reporting Guidelines

Foreign-Owned Domestic Disregarded Entities: The New Reporting Requirements

How the FBAR’s “Willfulness” Element Has Recently Evolved

An Update on International Tax Enforcement

Offshore Tax Evasion Remains on IRS “Dirty Dozen” List for 2017

Former University Professor sentenced to Prison for Hiding over $220 Million in Offshore Accounts—Pays $100 Million to Resolve FBAR Penalties

A Brief on the New Final Regulations For Shareholders of PFICs

The Swiss Bank Program: The Justice Department Announces Final Resolutions

FinCEN Announces Automatic FBAR Extension