On April 12, 2022, the Internal Revenue Service announced that starting this month, it will send letters to taxpayers requesting that they take corrective actions related to the reporting of investments in qualified...more
4/21/2022
/ Capital Gains ,
Corrective Actions ,
Enforcement Priorities ,
Income Taxes ,
IRS ,
Noncompliance ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Investments ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning ,
Tax Returns
The IRS continues to expand its enforcement activities, announcing a new compliance campaign to examine large businesses with issues arising out of the TCJA and CARES Act.
The IRS Large Business and International ("LB&I")...more
The Internal Revenue Service ("IRS") announced that as soon as it reopens its collection and examination functions on July 15, it will immediately begin the examination of hundreds of high-income individuals and private...more
7/13/2020
/ Closely Held Businesses ,
Estate Planning ,
Estate Tax ,
High Net-Worth ,
IRS ,
Partnerships ,
Private Foundations ,
Tax Audits ,
Tax Liability ,
Tax Planning ,
Trusts ,
Wealth Management
Court rules that a "John Doe" summons to obtain confidential client records from a law firm isn’t barred by attorney-client privilege.
On May 15, 2019, a district court in the Western District of Texas held that the...more
5/29/2019
/ Attorney-Client Privilege ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Failure to Report ,
FATCA ,
Government Investigations ,
IRS ,
John Doe Investigation ,
Offshore Drilling ,
Panama Papers ,
Paradise Papers ,
Privilege Logs ,
Reporting Requirements ,
Summons ,
Tax Evasion
An investigation of Belize-based stockbrokers recently led to the first FATCA conviction since its enactment in 2010.
The former head of an offshore bank pled guilty to conspiracy to defraud the United States by...more
9/19/2018
/ Criminal Prosecution ,
Department of Justice (DOJ) ,
FATCA ,
Foreign Bank Accounts ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Financial Institutions (FFI) ,
Indictments ,
Market Manipulation ,
Offshore Funds ,
Reporting Requirements ,
Tax Evasion
The U.S. Supreme Court today barred the government from prosecuting taxpayers for obstructing the administration of the Internal Revenue Code, unless it can show they acted in response to a pending or reasonably foreseeable...more
On March 13, 2018, the Internal Revenue Service ("IRS") announced that the Offshore Voluntary Disclosure Program ("OVDP") will end on September 28, 2018. The program has allowed taxpayers to avoid criminal prosecution by...more
Hackers leaked approximately 13.4 million confidential client documents from Appleby, Estera, and Asiaciti Trust to the International Consortium of Investigative Journalists....more
12/1/2017
/ Common Reporting Standard (CRS) ,
Customer Due Diligence (CDD) ,
Disclosure Requirements ,
FATCA ,
Financial Institutions ,
IRS ,
Leaked Information ,
OECD ,
Offshore Funds ,
Paradise Papers ,
Popular ,
Recordkeeping Requirements ,
Tax Planning