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IRS Increases Enforcement Efforts on Large Businesses

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

IRS Summons for Law Firm Client Data Is Enforceable

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

Taxpayers Cannot Sue Out-of-State Taxing Authorities in Local Courts

The Supreme Court ruling will prevent taxpayers from challenging assessments from out-of-state taxing authorities in local courts. On May 13, 2019, the U.S. Supreme Court ruled that states retain sovereign immunity from...more

First Conviction in the U.S. for FATCA Violations

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

U.S. Supreme Court: Government Went Too Far in Tax Obstruction Prosecution

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

IRS Announces End of Offshore Voluntary Disclosure Program

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

FinCEN: No SAR Filing Obligation When Customers Voluntarily Disclose to Home Country

On February 21, 2018, the Financial Crimes Enforcement Network ("FinCEN") issued highly anticipated guidance affecting reporting obligations for U.S. financial institutions in response to an inquiry by the Florida...more

Paradise Papers: The Latest Offshore Leak

Hackers leaked approximately 13.4 million confidential client documents from Appleby, Estera, and Asiaciti Trust to the International Consortium of Investigative Journalists....more

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