Lauryn Hill's Tax Evasion a 'Battle for Survival': Lawyer
When is a US Taxpayer required to disclose offshore accounts on an FBAR and IRS Form 8938? While many US taxpayers and expatriates have come to understand the requirements of the FinCEN Form 114 or FBAR, a surprising number...more
On September 8, 2023, the IRS issued a News Release suggesting that FBAR compliance investigations and audits would heat up in the near future. For those unfamiliar with FBARs, federal law requires United States persons to...more
In a monumental opinion, the Tax Court recently held that the IRS lacks authority to assess penalties imposed by IRC § 6038(b)(1) or (2). In Fahry v. Commissioner, the taxpayer failed to file Forms 5471 reporting his interest...more
Publication indicates a more robust enforcement posture - On October 20, 2022, the U.S. Department of the Treasury (“Treasury”) released the first-ever Enforcement and Penalty Guidelines (the “Guidelines”) for the...more
Since 2015, federal agencies have been required to annually review the laws and regulations they enforce to adjust applicable penalties for inflation. The idea has been to provide increasingly greater incentives for plan...more
In responding to the Securities and Exchange Commission’s recent Municipalities Continuing Disclosure Cooperation (MCDC) initiative, the unanswered question for many municipalities and broker-dealers was determining whether...more
A non-U.S. company that buys or sells U.S. real estate that is or once was used for agricultural purposes may face reporting requirements in connection with such transactions. These reporting obligations might apply whether...more