Blogs
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
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…