International Tax

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
Cross-Border Tax Insights, International Tax, Streamlined Filing, Voluntary Disclosure

The Updated IRS Voluntary Disclosure Program

By Freeman Law Feb 12, 2020
Cross-Border Tax Insights, International Tax, Partnership

Form 8865, U.S. Persons and Foreign Partnerships

By Jason B. Freeman Feb 06, 2020
Criminal, Cross-Border Tax Insights, Cryptocurrency, International Tax, Tax Fraud

Doctor Sentenced to 30 Months in Prison for Filing False Income Tax Return Involving Offshore Assets and Cryptocurrency

By Jason B. Freeman Jan 28, 2020
Cross-Border Tax Insights, Foreign Trusts, International Tax

IRS Form 3520 – Reporting Transactions with Foreign Trusts and the Receipt of Foreign Gifts

By Jason B. Freeman Jan 26, 2020