2d Circuit Holds that A U.S. Person Who Is Both Owner and Beneficiary of Foreign Trust Is Liable for Separate Penalties for Failure to Report in Both Categories (8/2/21)
Tax Court Finds Offshore Account Owner Not Credible; Determines Income Tax Deficiency and Civil Fraud Penalty (8/1/21)
Government Abuse of Rule 6(e)’s Grand Jury Secrecy Requirement (7/31/21)
D.C. SDNY Approves John Doe Summons re Offshore Enablers (7/30/21)
Teacher Certificate Revocation Based on Fraud in Defraud Conspiracy; Wrong
ABA Tax Section Recommendation to IRS for Priority Guidance to Disavow Application of WSLA and Further Comments Re Same (7/23/21)
Court Reverses TOP Offset Against Social Security Payments That Exceed Court's Restitution Schedule for Payments (7/21/21; 8/2/21)
