Exempt Payments to Non-Resident Aliens and Federal Withholding - Wages paid to U.S. citizens and residents by a U.S. person are generally subject to federal withholding, subject to certain exceptions. Wages paid to...more
Tax Litigation: The Week of April 4th, 2022, through April 8th, 2022 Middleton v. Comm’r, T.C. Memo. 2022-28 | April 4, 2022 |Kerrigan, J. | Dkt. No. 8158-19L Scholz v. Comm’r, T.C. Summary Opinion 2022-5 |April 4,...more
Money laundering is the process of disguising criminal proceeds—that is, the process of cleansing the taint from the proceeds of crime. Money laundering, as a very general matter, occurs when a person or organization earns...more
The Foreign Agents Registration Act (FARA), 22 U.S.C. § 611 et seq., is a federal statute passed in 1938 that was originally intended to combat the dissemination of Nazi and Communist propaganda within the United States. FARA...more
1/6/2022
/ Department of Justice (DOJ) ,
Foreign Agents ,
Foreign Agents Registration Act (FARA) ,
Foreign Corporations ,
Foreign Governments ,
Foreign Nationals ,
Lobbying ,
Lobbying Disclosure Act ,
National Security ,
Registration Requirement ,
Reporting Requirements
In January of 2021, the Anti-Money Laundering Act of 2020 (AMLA) went into effect, marking the most significant changes to federal anti-money laundering laws since the USA Patriot Act of 2001. The AMLA represents an attempt...more
12/14/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Beneficial Owner ,
Counter-Terrorist ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Financial Institutions ,
Law Enforcement ,
Reporting Requirements ,
Terrorist Financing Regulations ,
U.S. Treasury
DeFi, or decentralized finance, has experienced unprecedented growth over the last few years, resulting in a market cap of approximately $85 billion as of October 2021. Built on blockchain technology and cryptocurrency, DeFi...more
On August 10, 2021, the U.S. Senate passed a $1 trillion infrastructure bill after months of negotiations. Tucked away within the sweeping legislation are measures that would extend Form 1099-B and cost basis reporting...more
11/15/2021
/ 1099s ,
Bitcoin ,
Blockchain ,
Cryptocurrency ,
Digital Assets ,
Ethereum ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Reporting Requirements ,
Software Developers ,
U.S. Treasury
The 35% penalty under I.R.C. section 6677 for failing to report a distribution from a foreign trust applies against a person who is both the beneficiary and grantor/owner of a foreign trust. At least, that is now the rule...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
8/10/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
FBAR ,
FinCEN ,
Foreign Bank Accounts ,
IRS ,
Offshore Funds ,
Penalties ,
Reporting Requirements ,
Tax Returns ,
Willful Violations
In a recent decision, a federal district court found that a long-time CPA/tax-return preparer recklessly failed to file FBARs to disclose several foreign financial accounts. As avid readers of our Insights are aware, many...more
International information return penalties are civil penalties assessed by the IRS against a United States person for failing to timely file complete and accurate international information returns required by specific...more
10/8/2020
/ FBAR ,
Filing Requirements ,
Foreign Corporations ,
Foreign Tax Credits ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Reporting Requirements ,
Statute of Limitations ,
Tax Returns