Law Office News

Courts Split on FBAR non-willful Penalty
Should FBAR non-willful penalty be charged per form or per account? The Courts have recently…

Cash Intensive Businesses & the IRS; a marriage made in Hell
Cash intensive businesses Operating a cash intensive business is often accompanied by poor record keeping…

Quiet Disclosure Guilty Plea
Florida man pleads guilty to tax evasion and hiding funds around the world In April…

Real Estate Ownership in a self-directed Investment Retirement Account; avoiding the hidden risks
Real estate ownership in a Self-Directed Investment Retirement Account (IRA) can provide certain tax benefits…

Bank Fraud and Criminal Tax Charges Against Michael Avenatti
Michael Avenatti’s Indictment The temptation to use unfilled or altered tax returns as well as…

Taxing Foreign Corporations in the Digital Age
Effectively Connected Income and it’s Tax Consequences Foreign entities that deliver digital goods and services…

Good News for Rental Property Owners; Qualified Business Deduction
Business Income Deduction for Taxpayer On September 24, 2019, the IRS issued Revenue Procedure 2019-38 …

Tax Relief for Expats who Renounce U.S. Citizenship
Relief Procedures for former U.S. Citizens The new procedures attempt to address problems faced by…

Employment Tax Consequences with Workers Misclassification
Employee versus Independent Contractor Deciding whether to classify an individual as an employee or independent…

IRS Detection of Tax Fraud Proliferates
Data Analytics is the Key During the last decade, the Internal Revenue Service has been…

Residency Based Taxation Legislation Provides False Hope for U.S. Expats
Citizen Based Taxation The origins of citizen based taxation can be traced back to the…

Willful FBAR Penalty Moving Towards a Strict Liability Standard
Assessment of the “willful” FBAR penalty Courts have sustained FBAR penalties by reference to case…