Blogs
Appeals vs Exam: Strategic Mistakes Taxpayers Make
When an IRS audit leads to a disagreement, most people tend to focus just on…
Cross-Border IRS Asset Seizure
When you have assets outside the U.S., you may think the IRS can’t touch them.…
How FATCA Data Sharing Triggers IRS Audits
If you have foreign accounts, investments, or income outside the United States, you’ve probably wondered…
How Pillar Two Creates New IRS Audit Angles
Multinational companies spent years carefully planning taxes across different countries. Now those same global setups…
How FBAR Cases Are Selected for Criminal Investigation
Report of Foreign Bank and Financial Accounts, or FBAR, mistakes don’t all carry the same…
Second Circuit Rejects Tax Court’s Farhy Holding on § 6038 (b) Penalty Authority
Second Circuit Rejects Tax Court’s Farhy Holding on § 6038 (b) Penalty Authority
Safdieh v. Commissioner, ___ F.4th ___ (2d Cir. Feb. 27, 2026) Background In Farhy v.…
FBAR And FATCA Violations Becoming Criminal Tax Exposure
Many taxpayers think failing to file FATCA or FBAR forms is minor. The IRS does…
FBAR Penalties After Assessment: Litigation & Defense Options
An FBAR penalty changes things the moment it is assessed. What had been under review…
How IRS Agents Expand Audits Internally?
Many taxpayers think an IRS audit is limited to the one issue listed in the…
Navigating Form 8621 PFIC: A Practitioner’s Guide to PFIC Compliance, Elections, and Risk Management
Foreign investments have become increasingly common for U.S. taxpayers, but few areas of the Internal…
IRS 6-Year Rule: Statute of Limitations on Unfiled Tax Returns Explained
People who have unfilled tax returns often hear one phrase from friends, forums, and even…
FBAR Penalty Notice: Your 30-Day Legal Action Plan to Appeal or Negotiate with the IRS
An Internal Revenue Service (IRS) Report of Foreign Bank and Financial Accounts (FBAR) penalty notice…