International Tax

Cross-Border Tax Insights, FBAR, International Tax

Court Strikes Down Largest Non-Willful FBAR Penalty Ever

By Jason B. Freeman Jul 02, 2020
Cross-Border Tax Insights, FBAR, International Tax

Foreign Accounts and FBAR Penalties

By Jason B. Freeman Jun 24, 2020
Cross-Border Tax Insights, FBAR, International Tax

The Largest Non-Willful FBAR Penalty Case Ever?

By Jason B. Freeman Jun 18, 2020
Controlled Foreign Corporation (CFC), International Tax, Tax Court, The-Tax-Court-in-Brief Insights

Flume II: The Tax Court’s Recent Decision Involves UBS of Switzerland and Controlled Foreign Corporations

By Jason B. Freeman Jun 15, 2020
Cross-Border Tax Insights, International Tax, Tax Litigation Insights

Federal Court Dismisses Taxpayer’s $1.8 Million Refund Claim Due to Insufficient IRS Form 2848 Authorization

By Jason B. Freeman Jun 03, 2020
Criminal, Cross-Border Tax Insights, International Tax, Offshore Tax

U.S. Government Continues To Crack Down On Unreported Offshore Bank Accounts

By Jason B. Freeman May 24, 2020
Corporate, Cross-Border Tax Insights, International Tax, LLC

IRS Private Letter Ruling Allows Foreign LLC’s Late Entity-Classification Election

By Jason B. Freeman May 06, 2020
Cross-Border Tax Insights, Form 5471, International Tax

IRS Private Letter Ruling Allows Foreign Corporation’s Untimely Form 5471 Election

By Jason B. Freeman May 04, 2020
Cross-Border Tax Insights, International Tax, White-Collar Defense Insights

United States Ranks Second as Financial Secrecy Haven, Beating Out Switzerland

By Freeman Law Apr 28, 2020
Criminal, Cross-Border Tax Insights, FBAR, International Tax, Streamlined Filing, Tax Evasion, Voluntary Disclosure

The Danger of a Quiet Disclosure

By Freeman Law Apr 19, 2020
Bank Secrecy Act, Cross-Border Tax Insights, FATCA, FBAR, International Tax, Offshore Tax, Voluntary Disclosure

The Government’s Warning to Taxpayers: False Certifications of Non-Willfulness Will Be Prosecuted

By Freeman Law Apr 15, 2020
Criminal, Cross-Border Tax Insights, International Tax, White-Collar Defense Insights

International Taxes and Crimes: The “Revenue Rule,” RICO, and Wire Fraud

By Jason B. Freeman Apr 13, 2020
Cross-Border Tax Insights, FBAR, International Tax, OVDP

Recent FBAR Case: Signing and Not Reading Tax Return Leads to $900,000 Penalty

By Jason B. Freeman Mar 12, 2020
Cross-Border Tax Insights, International Tax, Penalties

Federal District Court Holds Passport Revocation Statute Constitutional

By Jason B. Freeman Mar 11, 2020
Cross-Border Tax Insights, Foreign Trusts, Form 3520, International Tax

The IRS Issues Significant Guidance on Foreign Trusts: Forms 3520 and Form 3520-A

By Jason B. Freeman Mar 04, 2020
Cross-Border Tax Insights, Gift & Estate Tax, International Tax, Penalties, Trust

Form 3520-A, Information Return of Foreign Trusts With a U.S. Owner

By Jason B. Freeman Feb 27, 2020
Cross-Border Tax Insights, Fraud, International Tax, Offshore Tax, Voluntary Disclosure

The J5 Continues its Efforts to Identify International Tax Cheats

By Jason B. Freeman Feb 21, 2020
Cross-Border Tax Insights, International Tax, Offshore Tax, Voluntary Disclosure

The Swiss Bank Program: Civil and Criminal Risk for Offshore Account Holders

By Freeman Law Feb 16, 2020