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What are the risks of an IRS quiet disclosure? Is there a formal IRS process known as a "quiet disclosure," and does the IRS honor this strategy for amended tax returns?...more
It is common for a US taxpayer to ask “what happens if you don’t file an FBAR or a Form 8938, Statement of Specified Foreign Assets with the IRS? Why do I have to worry about filing an FBAR in San Diego or anywhere in the US,...more
What is the IRS Offshore Voluntary Disclosure Program and who is it designed to help? What are the guidelines for voluntary disclosure to the IRS and who is eligible to apply? The IRS Offshore Voluntary Disclosure...more
Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to...more
Arkansas Men Convicted in $18 Million Global Investment Fraud Conspiracy - A federal jury in the Western District of Arkansas convicted four men of conspiracy to commit wire fraud, wire fraud, and conspiracy to commit money...more
On September 29, 2022, the Financial Crimes Enforcement Network (“FinCEN”) promulgated its much-anticipated Final Rule implementing the beneficial ownership reporting scheme mandated by the Corporate Transparency Act....more