- September 6, 2023On February 28, 2023, in Bittner v United States, 598 U.S. (2023) the U.S. Supreme Court, in a five to…
- September 5, 2023On June 26, 2023 the Supreme Court granted the Petitioners’ Application for a Writ of Certiorari for purposes of considering…
- January 18, 2023Prosecution for employment tax crimes in 2022, reflects an increase in investigations for employment tax violations by the Department of…
- November 4, 2022The U.S. Department of the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) recently issued its Final Rule under the Corporate…
- November 2, 2022The IRS estimates that individual taxpayers underreported their income tax on average by $245 billion each year for tax years…
- November 1, 2022The requirements for filing Form 5471 are quite complex and confusing. The obligation to file Form 5471 depends upon the…
- November 1, 2022A recent report (the “Report”) from The Treasury Inspector General for Tax Administration (“TIGTA”) addressing Non-Filing and Non-Reporting Compliance under…
- December 1, 2021The Fifth Circuit recently held in United States v. Bittner, ___ F. 4th ___ (5th Cir. 11/30/21) that the non-willful…
- November 20, 2021NAVIGATING THE FBAR PENALTY MITIGATION GUIDELINES Failure to report your foreign financial accounts on Report of Foreign Bank Account Reports…
- November 13, 2021The issue of whether the Government can repatriate a taxpayer’s foreign assets for purposes of satisfying a taxpayer’s outstanding FBAR…
