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Is it too late to correct past FBARs and file amended returns with the IRS? The net is closing in on U.S. taxpayers with unreported or under-reported domestic and offshore income and assets. The IRS has increased audits in...more
On October 28, 2024, the U.S. Department of the Treasury (Treasury) issued final regulations (“Final Rule”) implementing Executive Order 14105, which addresses investments by U.S. persons in certain identified technologies in...more
New export controls, new section 301 duties, new OFAC requirements, new de minimis rule, new DOJ corporate compliance guidance, new international guidance on Russian sanctions. September had it all....more
On Monday, September 23, DOJ’s Criminal Division announced updates to its guidance for evaluating corporate compliance programs (“ECCP”). Principal Deputy Assistant Attorney General Nicole Argentieri also delivered remarks...more
Many US taxpayers still have questions regarding offshore accounts and FBAR filing requirements and compliance. Is there a genuine risk their activities (or lack of compliance) will come to light? The definition of a US...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