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Taxation of Professional Athletes & Entertainers – Are You At Risk?
The Risks of Professional Athlete and Entertainer Taxation
Global sports and entertainment have created many new opportunities as well as challenges for those individuals, who are multi-jurisdictional earners. The IRS has taken a keen interest…

Offshore Tax Compliance Prosecutions by the IRS
Offshore Tax Compliance Update - Recent IRS Tax Prosecutions
The following convictions represent recent successful prosecutions by the Department of Justice, Tax Division and reinforce the Government’s commitment to ferret out tax cheats,…

Delinquent IRS Trust Fund Taxes Update
The Trust Fund Penalty for Delinquent IRS Trust Fund Taxes
If you owe back payroll taxes, you should hire a capable Tax Attorney, who is experienced and familiar with the rules pertaining to the application of the Trust Fund Penalty. The IRS…

FBAR Collections Ten Billion and Counting
IRS Releases 2016 Offshore Voluntary Compliance Statistics
On October 21, 2016 the IRS released the latest statistics on Taxpayers who have made disclosures under the Offshore Voluntary Disclosure Program (OVDP) or by using the Streamline…

Michigan Man Pleads Guilty To Tax Obstruction
"ANOTHER KNUCKLEHEAD BITES THE DUST"
The definition of a Knucklehead is“someone considered to be of questionable intelligence.”
On October 7, 2016 a Michigan business man plead guilty to tax obstruction for filing a false amended tax…

Outrunning the IRS: FBAR Statute of Limitations Guidelines
What Happens If Someone Fails to File an FBAR?
A wrinkle in the law for those with interests in or signature authority over foreign financial accounts, including bank accounts, brokerage accounts, mutual funds, trusts, or other type of foreign…

Money Laundering Is Tax Evasion
Money Laundering and Tax Evasion
Money laundering and tax evasion are closely related. The IRS has used money laundering statutes to help cut down on tax evasion. Money laundering may be seen as willful tax evasion. Hiding money will off course…

Tax Controversy: What to Do When You Get An Audit Letter
The phrase “tax controversy” is used in the legal profession to define tax disputes that originate between the IRS or a state tax agency and a Taxpayer, usually, but not always, originating from an audit.
Legal services offered as part…

FBAR Enforcement:
How and When the IRS Will Act?
How Does the IRS Enforce the FBAR?
The Report of Foreign Bank and Financial Accounts, (FBAR), is required when a U.S. Person has a financial interest in or signature authority over one or more foreign financial accounts with an aggregate…
How and When the IRS Will Act?

All or Nothing – Trust Fund Recovery Penalty under Section 6672
Many business owners believe that operating as a Corporation protects them from personal liability.
While oftentimes this is true, if a corporation does not pay income tax withholding and withheld Social Security, the IRS can and will pursue…
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