Blogs
Do You Need to Report Crypto on FBAR or FATCA in 2026?
No, not automatically. Under current FinCEN guidance, a foreign account that holds only crypto stays…
Form 5471: Do You Own a Foreign Business the IRS Doesn’t Know About?
If you own stock in a foreign company, sit on its board, or helped set…
Form 3520 and 3520-A: IRS Enforcement Is Increasing
Form 3520 and Form 3520-A are information returns, not tax returns. They report what happened…
The Growing Role of IRS-CI in Cryptocurrency Enforcement
IRS-CI now plays a major role in cases involving hidden crypto income, false returns, money…
OBBBA and FATCA Thresholds: What Treasury’s New Authority to Lower Reporting Limits Means for You
The One Big Beautiful Bill Act (OBBBA) did not lower the FATCA or Form 8938…
Residence-Based Taxation Bill 2026: Should Expats Wait Before Filing a Streamlined Disclosure?
Waiting for the residence-based taxation bill before filing a streamlined disclosure is not the right…
Inside IRS Criminal Investigation: How IRS-CI Builds a Tax Evasion Case
An IRS criminal investigation examines suspected federal tax crimes and related financial crimes. The IRS…
IRS Voluntary Disclosure Practice in 2026: The Successor to OVDP for Willful Violations
The Offshore Voluntary Disclosure Program (OVDP) closed on September 28, 2018. What replaced it is…
FBAR Willful Penalties After United States v. Reyes: Reckless Disregard Is Now Enough
A civil FBAR violation can be “willful” even when the taxpayer did not knowingly break…
Form 1099-DA Is Here: What Crypto Investors Must Do Before the IRS Matches Your Records
Form 1099-DA is an information return that tells the IRS what a broker recorded for…
When Does a Civil Tax Audit Become a Criminal Investigation?
A civil tax audit turns into a criminal investigation when the IRS finds affirmative acts…
IRS Special Agents, Search Warrants, and Grand Juries: What Happens in a Criminal Tax Case?
An IRS criminal tax case moves through a defined sequence: referral, special agent investigation, evidence…