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The Evolving Standard of “Willfulness” in FBAR Cases: Where are We Now?

February 10, 2022

Willful FBAR Penalties and a District Court’s Authority to Remand IRS Willful Penalty Computations

January 26, 2022

Criminal Tax Statutes of Limitations and Suspensions: 18 U.S.C. § 3292 and the Fifth Circuit’s Decision in Pursley

January 19, 2022

Common Mistakes in Submitting an IRS Streamlined Filing Compliance Procedure Submission: And a Discussion of Professional Malpractice

January 14, 2022

The Art of an IRS APA Defense: Conservation Easements and Hewitt

January 9, 2022

26 U.S.C. § 6672 – Failure to Collect and Pay Over Tax, or Attempt to Evade or Defeat Tax

January 2, 2022

The IRS’s Renewed Focus on Abusive Trust Arrangements

December 28, 2021

IRS Targets Participants in Malta Pension Plan Transactions

December 22, 2021

Challenging FBAR Penalties in Federal Court: FBAR Litigation

December 17, 2021

Is My Foreign Retirement Account Subject to IRS Information Return Reporting (FBAR, 3520, etc.)?

December 13, 2021

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