News & Analysis as of

Internal Revenue Service FinCEN

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Allen Barron, Inc.

Why You Need a Lawyer for an IRS Audit

Allen Barron, Inc. on

Why do you need a lawyer for an IRS audit? Have you received an IRS audit notification (IRS form letter 2205-A, 2205-B, or 566)? What do you need to know?...more

Allen Barron, Inc.

Tax Developments for US Expatriates

Allen Barron, Inc. on

There have been many recent tax developments for U.S. expatriates. It is essential for U.S. citizens residing outside the United States and those considering an expat life to understand their responsibilities as U.S....more

Polsinelli

Blockchain+ Bi-Weekly; Highlights of the Last Two Weeks in Web3 Law: March 27, 2025

Polsinelli on

The past two weeks brought some notable progress for the industry, though it still often feels like “regulation by lack of enforcement” rather than a truly proactive approach. The SEC clarified that most proof-of-work mining...more

Freeman Law

Willful FBAR Penalties and the Excessive Fines Clause: District Court Says Context is Key

Freeman Law on

In its recent decision in United States v. Leeds, the United States District Court for the District of Idaho upheld the application of willful penalties against a deceased husband for failing to report certain foreign bank...more

Paul Hastings LLP

Latest Executive and Legislative Actions Continue Crypto-Friendly Movement

Paul Hastings LLP on

The past two weeks have been a whirlwind of activity for the financial and crypto sectors, with developments on Capitol Hill and from key regulatory agencies. President Donald Trump’s nomination of Michelle Bowman as the...more

Baker Botts L.L.P.

Taxpayer Assistance and Service Act – Tax Controversy Perspective

Baker Botts L.L.P. on

On January 30, 2025, a bipartisan group of US Senators released a discussion draft of the Taxpayer Assistance and Service Act (“TAS Act”), a legislative proposal that, if passed, could significantly alter tax controversy...more

ArentFox Schiff

The Big Six Items That Family Offices Need to Consider in 2025

ArentFox Schiff on

Across all industries, family offices and their owners and management teams face rapidly evolving challenges, opportunities, and risks in the dynamic environment that is 2025. Here are six issues that family offices should...more

ArentFox Schiff

What Private Companies and Family Offices Need to Consider in 2025

ArentFox Schiff on

Across all industries, private companies, family offices, and their owners and management teams face rapidly evolving challenges, opportunities, and risks in the dynamic environment that is 2025. Here are 11 issues that...more

Haynsworth Sinkler Boyd, P.A.

New Deadlines for FINCEN Compliance Issued

The Corporate Transparency Act (CTA) introduced substantial new reporting obligations for a wide array of corporate entities. Generally, any domestic entity formed by filing documents with a secretary of state or similar...more

Allen Barron, Inc.

International Business and Offshore Investment and Banking Create Genuine IRS Risk

Allen Barron, Inc. on

International business and offshore investment and banking create genuine risk and exposure with the IRS. This extends to real estate ownership outside of the U.S. and other offshore-related financial activities, which raise...more

Foodman CPAs & Advisors

NTA Addresses Overlap Reporting

On 1/8/25, the National Taxpayer Advocate (NTA) published its 2024 Annual Report to Congress and identified taxpayers’ problems and provided suggestions to further protect taxpayer rights and ease taxpayer burden. “By law,...more

Allen Barron, Inc.

A Foreign Trust Creates Complex IRS Reporting Requirements

Allen Barron, Inc. on

The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more

Latham & Watkins LLP

Regulatory Reversals: Political Transitions and the Congressional Review Act

Latham & Watkins LLP on

A Republican Congress and the incoming Trump administration may employ the CRA to quickly overturn recent rules that faced heavy criticism from the financial services industry....more

Allen Barron, Inc.

Foreign Corporate Ownership and Investments

Allen Barron, Inc. on

Are you involved in offshore or foreign corporate ownership and investments? Do you have real property, assets, or foreign bank or investment accounts? U.S. taxpayers with offshore business interests, holdings, investments,...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Final Regulations Applicable for Front-End Service Providers Facilitating Digital Asset and...

On December 30, 2024, the Department of the Treasury (the Treasury) and the Internal Revenue Service (the IRS) published the final regulations (Final DeFi Regulations) relating primarily to persons who are front-end service...more

Morgan Lewis

Five Developments Family Offices Are Watching in 2025

Morgan Lewis on

As family offices continue to adapt to economic, financial, and technological changes, several ongoing developments are giving family offices plenty consider heading into 2025, including gift and estate tax exemptions, which...more

Holland & Hart LLP

the buzz: Cannabis News & Policy Update - December 2024

Holland & Hart LLP on

Welcome back to the buzz, our monthly cannabis news and policy update. Your at-a-glance source for regulatory developments, agency announcements, and trends impacting the cannabis industry. In this edition of the buzz,...more

Polsinelli

Disregarded Entity Eligibility for the CTA Large Operating Company Exemption

Polsinelli on

As discussed in detail below, the Corporate Transparency Act (CTA) provides an exemption to its reporting requirements for certain large operating companies (the Large Operating Company Exemption or “LOC Exemption”). In order...more

Foodman CPAs & Advisors

BOI Reporting Relief for Hurricane Victims

On 10/29/24, FinCEN announced Beneficial Ownership Information (BOI) Reporting Relief to specific victims of Hurricane Milton, Hurricane Helene, Hurricane Debby, Hurricane Beryl, and Hurricane Francine. BOI Reporting Relief...more

Allen Barron, Inc.

What is Willful Blindness According to the IRS?

Allen Barron, Inc. on

What is willful blindness according to the IRS? How is this important in tax cases involving unreported or under-reported income, disclosure of offshore assets and income, FinCEN Form 114 (more commonly referred to as an...more

Haynsworth Sinkler Boyd, P.A.

Navigating FinCEN Compliance: Quickly Approaching Deadlines for Businesses formed before 2024

A variety of businesses, such as LLCs, LLPs, partnerships, and corporations, formed before January 1, 2024, have until January 1, 2025, to file their initial report with the Department of Treasury’s Financial Crimes...more

Wiley Rein LLP

FinCEN Extends Corporate Transparency Act Filing Deadline for Certain Companies Impacted by Recent Hurricanes

Wiley Rein LLP on

The Financial Crimes Enforcement Network (FinCEN) recently announced that it will provide a six-month Corporate Transparency Act (CTA) filing extension to certain reporting companies affected by one of the five hurricanes in...more

Smith Anderson

The Corporate Transparency Act: Extensions of Reporting Deadlines to Victims of Recent Natural Disasters

Smith Anderson on

As discussed in our four prior client alerts below, effective as of January 1, 2024, the Corporate Transparency Act (“CTA”) and rules issued thereunder by the Financial Crime Enforcement Network (“FinCEN”) require most U.S...more

Allen Barron, Inc.

Is it Too Late to Correct Past FBARs and File Amended Returns with the IRS?

Allen Barron, Inc. on

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

Vinson & Elkins LLP

FinCEN Extends BOI Reporting Deadlines for Businesses Impacted by Recent Hurricanes

Vinson & Elkins LLP on

The Financial Crimes Enforcement Network (“FinCEN”) has announced temporary relief measures for reporting companies affected by recent hurricanes in the Southeast, providing additional time to comply with Beneficial Ownership...more

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