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Do I Need to File an FBAR for FY 2023 (and What Happens If I Don’t)?

Taxpayers that own (or control) offshore bank accounts and other foreign financial assets have a duty to report these assets to the federal government annually. While there are minimum thresholds for taxpayers’ reporting obligations, these thresholds are fairly low—so most high-income and high-net-worth taxpayers will need to comply. Typically, this […]


I Received a Letter from IRS Criminal Investigation (IRS CI). What Now?

IRS Criminal Investigation (IRS CI) conducts inquiries targeting a wide range of both tax-related and non-tax-related offenses—and these inquiries can present substantial risks for high-asset and high-income taxpayers. This includes not only the risk of substantial liability for back taxes, interest and fines, but also the risk of federal incarceration. […]


What Do You Need to Know if You Received a Summons from the IRS?

When targeting taxpayers for fraud and other crimes, the Internal Revenue Service (IRS) has various investigative tools at its disposal. One of these tools is the summons. The IRS routinely issues summonses in order to obtain information in furtherance of its enforcement efforts, and these summonses can present significant risks […]