Willfulness is usually required to support criminal charges. Assigning signature authority to someone else to conceal account ownership could show willful conduct. Filing a document, such as a Foreign Bank and Financial Accounts/FinCEN Report 114 (FBAR) with false information is another. A five year prison sentence is on the table […]
It seems so basic: Did you file a return or didn’t you? Rather remarkably, however, even this seemingly straightforward question can result in litigation. In this post, we will discuss a recent case in which one of the issues was proving that a return was filed. The case is called […]
The IRS’s budget has been going down, not up. These cuts have made the agency less able to play its accustomed customer-service role in helping taxpayers comply with the U.S. tax code. To be sure, the IRS also has its enforcement side, with penalties, audits, investigations and collection actions. Could […]
College athletes still aren’t paid (other than receiving scholarships). But the role of agents and advisers is very important in helping players procure pro contracts and managing their money if and when they do. Like other financial advisers, those who represent athletes can run afoul of tax authorities. In this […]
Federal regulation of businesses is poised to change with the new administration, with important implications for tax compliance. President-elect Trump has promised to roll back business regulation across the board. And with his surprising victory this week, he is in a position to put that promise into practice. But it […]
The IRS has reportedly received more than 8,000 public comments regarding proposed changes to how the agency determines valuation discounts under Section 2704 of the U.S. Tax Code. This provision, contained in Reg-163113-02 of the agency’s regulations, deal with discounts allowed for valuation of business holdings and assets for purposes of calculating […]
According to some sources, Google searches for “emigrating to Canada,” “moving abroad” and “leaving the U.S.” (among others) spiked the night of the first election debate between Hillary Clinton and Donald Trump. Say what you will about either candidate, the truth remains that this election cycle has been a tumultuous […]
Contentious tax litigation can take a very long time to resolve. For over two years, we’ve been following a complicated fraud and tax evasion case involving two Texas brothers, Charles and Sam Wyly, who set up a series of offshore tax shelters that ran afoul of federal regulators. The twists […]
This past week, news hit the airwaves about a former U.S. Tax Court judge who pleaded guilty to violation of federal tax law. This dramatic story speaks to every taxpayer with the message that anyone of any stature or with any level of education can potentially face criminal tax charges. It also […]
While it’s not against the law to own a foreign bank account, the tax code requires that you disclose it and pay tax on income. Since 2009, the IRS has devoted significant resources to offshore account compliance. A couple years ago, we wrote an article with an update on the […]