From Permits to Penalties: A Deep Dive Into Coastal Development Law
PODCAST: Williams Mullen's Benefits Companion - Forfeitures Under Fire
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Episode 371 -- DOJ's New Corporate Enforcement Program
REFRESH Nonprofit Basics: Federal Tax Filing Deadlines and Penalties
Episode 369 -- Stepping Into the Enforcement Spotlight -- Customs and Border Patrol and Import Enforcement
Insider Transaction Traps for the Unwary
Nonprofit Basics: Federal Tax Filing Deadlines and Penalties
JONES DAY PRESENTS®: Harmonizing Global Protections: The EU Trade Secret Directive
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Economic Substance: Practical Advice 3 Years On …
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#WorkforceWednesday: OSHA Issues COVID-19 Citations, Michigan Enacts Liability Shield, and States Battle for Telecommuter Taxes - Employment Law This Week®
False Claims Act Implications for PPP and Disaster Relief Loans: What Small Businesses Should Be Ready For
Litigation and COVID-19: How to Protect Your Business in This Time of Crisis
JONES DAY PRESENTS®: Insurance Implications of the California Consumer Privacy Act
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ITAR – Requirements for Government Contractors
This Week in FCPA-Episode 56
Your Cyber Minute: Current GDPR regulatory and enforcement landscape
How many U.S. taxpayers and expatriates may need to file offshore disclosures and FBARs with the IRS? Should those who have not yet filed a disclosure application utilize the VDP (Voluntary Disclosure Program) or a...more
The world is an ever-changing, ever-evolving crucible of financial and other serious challenges for expats and those considering moving abroad, as well as foreign nationals living and working in the United States. Oversight,...more
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
How does the IRS define willfulness in unreported or under-reported offshore income? What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct? Why should U.S. taxpayers be...more
Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...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
Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to...more
On September 8, 2023, the IRS issued a News Release suggesting that FBAR compliance investigations and audits would heat up in the near future. For those unfamiliar with FBARs, federal law requires United States persons to...more
On Feb. 28, the U.S. Supreme Court ruled that non-willful penalties related to FBARs apply to each report filed, not on a per-account basis. The 5-4 decision resolved a split between the Fifth and Ninth circuits that focused...more
It’s that time of year again. Various football teams scramble at the end of the regular season for a chance at the playoffs. And with each game’s conclusion spectators get an updated “playoff picture” with respect to where...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
At the 34th Annual National Institute on Criminal Tax Fraud in Las Vegas yesterday afternoon, Mark Daly, DOJ Tax Division Senior Litigation Counsel announced a major new shift in how the Department of Justice plans to argue...more
Since 2009, the number of FBAR penalties imposed for failures to report foreign bank accounts and the size of the penalties have both increased dramatically. Originally published in The Tax Advisor....more
We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...more