...criminal prosecution and successfully resolve their tax liabilities. The IRS proposal outlined significant changes in three broad areas: disclosure and compliance requirements, the penalty framework, and application and processing procedures....
...Internal Revenue Service (IRS). Last month, the National Taxpayer Advocate recommended a legislative solution to amend the Internal Revenue Code and the Bank Secrecy Act to eliminate this duplication. For...
...for personal enrichment, including the purchase of luxury real estate and securities. The High Stakes of IRS-CI Involvement IRS Criminal Investigation (IRS-CI) is the only agency with jurisdiction over violations...
Despite major budget cuts and layoffs, the Internal Revenue Service Criminal Investigation (IRS-CI) division continues to demonstrate its proficiency in untangling complex “off-the-books” financial arrangements. A recent case out of...
Can a taxpayer’s good-faith reliance on tax preparation software serve as a defense against IRS penalties? The U.S. District Court for the Northern District of California recently addressed this issue...
...a full examination. How and when will a taxpayer know if the IRS has accepted their returns?Taxpayers will receive written confirmation once IRS processing is complete. Timing may vary depending...
On January 7, 2026, the United States Court of Appeals for the Second Circuit issued its opinion in United States v. Reyes, holding that “willfulness” for purposes of civil FBAR...
...workers remains absolute. With an increasing move toward e-filed, data-driven reporting, the IRS will find it easier to detect mismatches. Businesses should review independent contractor policies rather than simply issuing...
...via IRS Form 3520, a document that has increasingly become a focal point for aggressive IRS penalty enforcement. We have recently seen many Form 3520 penalty cases. As we move...
...of the modern IRS, especially in IRS Appeals or Exams, our firm provides the specialized tax law counsel necessary to ensure every submission successfully meets the highest standard of review....
...that this population would be less likely to file federal income tax returns or alert the IRS to the companies’ ongoing failure to account for and pay over the taxes....
...(OBBB Act). (NJCPA). Additional highlights included IRS enforcement updates and new reporting and compliance requirements for accountants and their clients. (NJCPA) This presentation, part of the NJCPA’s Membership+ benefit program,...
