...requires highly specialized legal analysis and sophisticated procedural advocacy. When your clients face undisclosed foreign bank accounts, complex trust assets, or active international audits, we regularly partner with CPAs, EAs,...
...in complex international tax controversies and administrative procedures. If you require specialized co-counsel or strategic guidance regarding a client’s undisclosed offshore accounts, please contact us to schedule a formal consultation....
...of documents to claim retroactive tax benefits. Concealment of Assets: Utilizing nominee accounts, structuring transactions to evade cash reporting requirements, or failing to disclose foreign financial accounts. Conscious Avoidance: Situations...
The enforcement of Foreign Bank and Financial Accounts (FBAR) reporting requirements remains one of the highest-stakes areas of tax controversy practice. The IRS continues to aggressively pursue maximum willful penalties...
...clients from severe civil and criminal liabilities. A primary driver of this sustained enforcement is the PPP and Bank Fraud Enforcement Harmonization Act of 2022. This legislation extended the statute...
...to a fintech-originated loan was generally subject to a five-year wire fraud limitations period; bank-originated loans already carried a ten-year period under the federal bank fraud statute, 18 U.S.C. §...
...practitioners should review accounts for any client who, between January 20, 2020, and July 10, 2023, experienced the following: Assessed Failure-to-File penalties under IRC Section 6651(a)(1). Assessed Failure-to-Pay penalties under...
...IRS Criminal Investigation Division increases its scrutiny of domestic and offshore activities, understanding how a civil audit converts into a criminal prosecution is essential. Key takeaways from this session will...
...respect of a decedent under Section 691. Common examples of IRD assets include: Traditional IRAs and 401(k) accounts. Unpaid wages, bonuses, or commissions. Installment notes receivable. Beneficiaries who inherit these...
...thresholds. FinCEN Form 114 (FBAR) If a U.S. person has a financial interest in, or signature authority over, foreign bank or financial accounts held by a foreign trust, they must...
...disclosure a viable option for a significantly larger group of taxpayers, particularly those with offshore accounts, digital asset activity, or international information return obligations who have been deterred by the...
...financial assets” if they meet certain value thresholds (generally starting at $50,000). Because “specified foreign financial assets” under the tax code largely overlap with “financial accounts” under the Bank Secrecy...
