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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…
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…
What Triggers an IRS Criminal Investigation?
Criminal investigations generally require evidence of intentional wrongdoing, not a simple mistake or an inability…
The DOJ’s Changing Crypto Enforcement Strategy: What Taxpayers Need to Know
The Department of Justice made a shift away from regulation by prosecution on April 7,…
How Blockchain Analytics Is Changing Criminal Tax Investigations
Blockchain analytics is changing criminal tax investigations by turning public transaction data into evidence investigators…
Missed FBAR and Tax Filing as an Expat? Best Legal Options to Fix Both Together
If you missed FBAR and your U.S. tax return in the same year, one IRS…
How to File US Taxes from Overseas Without Costly Mistakes or Delays
Americans living abroad must file a US tax return every year, even if they owe…
Can You Fix Offshore Tax Evasion Before the IRS Contacts You?
Taxpayers can often resolve offshore tax evasion legally if they act before the IRS initiates…
IRS Filed a Return for You (SFR)? How to Replace It and Reduce What You Owe
If the IRS filed a tax return on your behalf, you need IRS substitute return…
Can Cryptocurrency Transactions Still Be Hidden from the IRS?
You cannot hide cryptocurrency transactions from the IRS. Cryptocurrency is harder to hide from the…
Crypto and Tax Crime Watch: Why Digital Assets Remain a Top IRS Enforcement Priority
Digital assets remain a top IRS enforcement priority because every blockchain transaction leaves a permanent,…