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Navigating the US Estate Portability Election: Strategic Timing and Compliance Procedures for Form 706

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Navigating the US Estate Portability Election: Strategic Timing and Compliance Procedures for Form 706

13 July, 2026

...executor wishes to opt out of porting the DSUE, they must check the specific box in Part 6 of the return or affirmatively attach a statement to that effect. Complete...

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New Escalating Wave of PPP Enforcement: Key Takeaways for New Jersey Employers and Tax Professionals

26 June, 2026

The enforcement landscape surrounding the Paycheck Protection Program (PPP) has entered a highly aggressive enforcement phase. What began as an administrative process managed by the Small Business Administration (SBA) has...

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The High Cost of Cash: Analyzing the $3 Million Tax Evasion Sentencing of a Contractor

2 February, 2026

...practices, the defendant engaged in a multi-year effort to conceal the business’s true economic activity. The scheme involved several critical failures of compliance: Check Cashing and Commingling: Instead of depositing...

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The IRS Starts Using AI in Tax Functions

27 November, 2025

...Manual (IRM)) risks being efficiently triaged toward an adverse or delayed outcome. Increased Rigor in Chief Counsel: By assisting Chief Counsel attorneys with legal research and internal memoranda, AI enables...

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Winners and Losers in the “One Big Beautiful Bill Act”: A Tax Lawyer’s Perspective

8 July, 2025

...a potential incentive to purchase domestically-produced vehicles. Manufacturing & Research Sectors Immediate expensing for domestic research and development costs has been permanently reinstated. Small businesses with gross receipts of $31...

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Live Webinar on U.S.-India Tax Planning: Key Issues, Tax Treaties: Limited Free Registrations Available

9 December, 2024

...ties resulting in a constant flow of cross-border business transactions and citizens migrating between the two countries. Tax counsel and advisers must navigate challenges from interpreting and enforcing U.S. and...

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Middlesex County Man Admits Structuring over $250,000 in Deposits to Evade Reporting Requirements

1 November, 2024

...identify and mitigate risks. When in doubt, consult a legal professional to ensure that transactions are lawfully conducted. For further details, refer to the Department of Justice press release: https://www.justice.gov/usao-nj/pr/middlesex-county-man-admits-structuring-over-250000-deposits-evade-reporting...

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New IRS Website for New Immigrants to the United States: Key Tax Responsibilities

16 October, 2024

...impacts your tax obligations. Resident Alien for Tax Purposes: You may be classified as a resident for tax purposes if you hold a Green Card (Lawful Permanent Resident) or meet...

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IRS Criminal Investigations: A Serious Threat With Warning Signs

2 July, 2024

...potentially leading to personal, social, and financial ruin, professional license revocation, substantial fines, and even imprisonment. Recognizing the Warning Signs Often, taxpayers remain unaware of an ongoing criminal investigation until...

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Handling an Unexpected Visit from IRS Criminal Investigation: Guidance for Taxpayers and Advisors

28 June, 2024

...legal counsel. In fact, it is often advisable to do so, as it allows for a more controlled and strategic approach to resolving the matter. Protection of Rights: Engaging legal...

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Top Six Criminal Tax Questions Asked

27 May, 2024

...A: In the event of an unanticipated visit from IRS special agents, it is imperative to maintain composure and refrain from engaging in any conversation without seeking legal counsel. These...

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“Beneficial Owner” Analysis under the new Corporate Transparency Act

6 December, 2023

Starting January 1, 2024, the Corporate Transparency Act (CTA) will require most U.S. corporations, LLCs, and other legal entities formed through state filings or foreign entities registered to do business...

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Recent Posts

  • Navigating the US Estate Portability Election: Strategic Timing and Compliance Procedures for Form 706July 13, 2026
  • IRS Transitions from First Time Abatement to Automated Penalty Relief: Strategic Impacts for Tax AdvisorsJuly 11, 2026
  • Parag Patel to Present on IRS Foreign Asset Enforcement at the 2026 NATP TaxposiumJuly 9, 2026
  • The End of the IRS Delinquent FBAR Submission Procedures?: Still Available under IRM 4.26.16.3.11July 8, 2026
  • Parag Patel Speaks at 2026 NJCPA Convention: Navigating the High Stakes of Criminal TaxJuly 3, 2026
  • New Court Case on FBAR Penalty LimitsJuly 1, 2026
  • New Escalating Wave of PPP Enforcement: Key Takeaways for New Jersey Employers and Tax ProfessionalsJune 26, 2026
  • Establishing Depreciation Basis for Inherited Rental Properties: A Guide for Tax ProfessionalsJune 26, 2026
  • PPP Loan Fraud Enforcement Intensifies: What Employers Need to Know in 2026June 20, 2026
  • New Penalty Landscape: Analyzing the October 2025 Updates to IRM 21.8.2.19.2 for Late-Filed Forms 3520May 27, 2026

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