Tax Law Blog

There is an expectation by the Internal Revenue Service (IRS) that U.S. persons are aware that their income is taxed on a global basis—although the U.S. is one of very few countries that do so. Failure to file required reporting on assets outside of...

Years after the stunning revelations fueled by the Panama Papers, Nordea Bank was charged by Danish authorities with involvement in $3.7 billion in questionable transactions. Stateside, Nordea recently settled allegations by New York authorities...

Offshore tax havens, foreign bank accounts, and shell companies are legitimate tools often used for wealth management, asset protection, and tax planning. For many, these strategies provide essential support in navigating complex global financial...

The Internal Revenue Service (IRS) is synonymous with tax collection and tax enforcement. The enforcement unit within the IRS that investigates and pursues tax crime is called Criminal Investigation (IRS:CI).

Each year, the Internal Revenue Service (IRS) compiles a list of prominent tax schemes that scammers use to exploit individuals and businesses. These schemes can arrive through email, text messages, and even traditional mail. This year, the IRS has...

If you have a foreign bank account, hold assets or have an interest in an offshore tax account, you are required to file a Report of Foreign Bank and Financial Accounts (FBAR). If you failed to file in the last year, the Internal Revenue Service...

To the dismay of those with foreign business holdings, the Supreme Court of the United States (SCOTUS) upheld a transition tax on the unrealized profits of foreign business entities owned by American taxpayers.

Saving the best for last, the top two IRS:CI tax fraud matters of 2023 take a broad swipe at a multitude of IRS regulations from failure to file an FBAR report to money laundering, and tax fraud based on biofuel tax credits.

The Internal Revenue Service (IRS) is using its historic underfunding to explain why it has failed to pursue high-asset Americans taking unlawful advantage of tax breaks in Puerto Rico.

The nature of a tax controversy hinges on whether a misstep or mistake was willful or non-willful. If you are challenged by the Internal Revenue Service (IRS), knowing and being able to prove the difference can have big implications for penalties...