Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
Domestic Tax Planning - Podcast with Janathan Allen
Let's Talk About Taxes and Divorce
Nonprofit Basics: Operating Foundation Rules
Podcast: Got Mail? What to Do When the IRS Contacts You [More with McGlinchey, Ep. 42]
Let's Talk What to Bring to Your First Family Law Appointment
The Renoir Spelling Bee
The Presumption of Innocence Podcast: Episode 2 - Avoid Falling Prey: The Dirty Dozen and Other Trending Tax Scams
PODCAST: Williams Mullen's Benefits Companion - Plan Administrators’ 2020 Year-End Checklist
The Freeman Law Project – Episode 22 – Trump v. Vance - The Second Circuit Weigh In
The Freeman Law Project – Episode 21 – The New York Times and President Trump's Taxes
On-Demand Webinar | PPP Loan Forgiveness: Employment and Tax Issues for Borrowers
Williams Mullen's Comeback Plan: Part I – State & Local Tax (SALT) Compliance During COVID-19: What to Do When You’re Behind
Jones Day Presents: LB&I Examination Strategies: Process Overview
Jones Day Presents: Strategies for Dealing with the IRS: Going to Court
This Week in FCPA-Episode 56
On 10/12/23, the IRS announced new tax gap projections for tax years 2020 and 2021 showing the projected gross tax gap increased to $688 billion in tax year 2021, a rise of more than $192 billion from the prior estimates for...more
The National Taxpayer Advocate 2023 Annual Report to Congress highlights how Taxpayers abroad are underserved and continue to face challenges in meeting their U.S. tax obligations. As a result, the National Taxpayer Advocate...more
How does the IRS define willfulness in unreported or under-reported offshore income? What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct? Why should U.S. taxpayers be...more
Many Americans have not noticed the paragraph above their signature line on the 1040 and other IRS and state tax forms, which notifies the taxpayer that they signed their tax return "under the penalties of perjury" and that...more
What do you need to know about the IRS updated Streamlined Filing Compliance Procedures or "Streamlined Procedures?" Are you concerned about unreported or under-reported offshore income or assets? Are there accounts you...more
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
What are the IRS streamlined filing compliance procedures (known more commonly as the “streamlined procedures”), and when should a US taxpayer consider the IRS streamlined procedures to come into compliance with IRS reporting...more
US tax filing is underway, and as we approach the April 15 deadline we would like to offer additional tax updates and information for US expatriates. The first and most important thing for US expatriates to know about taxes...more
For many organizations and individuals, the end of the calendar year generates significant reporting obligations, particularly with respect to the Internal Revenue Service. The following requirements may not be obvious, but...more
Could Artificial Intelligence (AI) increase the likelihood of an IRS audit in your future? How does the IRS use AI to identify US taxpayers who attempt to hide assets, under-report income or otherwise cheat the IRS? In...more
In 2009, the IRS created its Global High Wealth Industry Group, known more familiarly as the “Wealth Squad.” This group starts with an examination of a “key case,” which is typically a wealthy person’s individual tax return,...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
Harrington v. Commissioner - In Harrington v. Commissioner of Internal Revenue, George S. Harrington (Harrington) challenged tax deficiencies and fraud penalties assessed for tax years 2005 through 2010. Originally...more
Taxpayers recently won a significant victory at the Supreme Court in a penalty case involving a non-willful failure to file a Report of Foreign Bank and Financial Accounts (“FBAR”) under the Bank Secrecy Act (the “BSA”)....more
After years of litigation, the United States Supreme Court, in Bittner v. United States, 598 U.S. ____ (2023), determined that the penalty for a non-willful failure to file a Report of Foreign Bank and Financial Accounts...more
Muchos ciudadanos americanos que viven en el extranjero no presentan su declaración de impuestos en Estados Unidos de América (“EUA”) por diversas cuestiones. Generalmente, esto sucede porque se tiene la creencia que no es...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 10, 2022 – October 14, 2022...more
Tax Litigation: The Week of September 12th, 2022, through September 16th, 2022 Degourville v. Comm’r, T.C. Memo. 2022-93 | September 12, 2022 | Wells, J. | Dkt. No. 4369-16 Fabian v. Comm’r, T.C. Memo 2022-94| September 13,...more
FBAR Penalties - On March 8, 2022, the Southern District of New York issued its Opinion in the case of United States v. Schik, No. 20-cv-0221 (MKV), 2022 U.S. Dist. Lexis 41148 (S.D.N.Y. Mar. 8, 2022). In that case, the...more
Willful FBAR Penalties - The Schwarzbaum case has received a lot of attention in the last few years from tax professionals. For example, in 2020, the district court concluded—contrary to some other federal court...more
It’s that time of year again. Various football teams scramble at the end of the regular season for a chance at the playoffs. And with each game’s conclusion spectators get an updated “playoff picture” with respect to where...more
On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account...more
A recent IRS Criminal Investigation press release announced an indictment against a businessman charged with defrauding the United States by not disclosing offshore assets, failing to report income to the IRS, and submitting...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 27, 2021 – October 1, 2021... September 28, 2021: The IRS released a revenue...more
A federal district court in Texas recently took up an interesting FBAR issue: whether civil FBAR penalties survive death? That is, if a taxpayer/account holder dies after the IRS assesses an FBAR penalty against them, do the...more