In Flint v. United States, 2022 WL 3593826 (Fed. Cl. 2022), the court held that the executors of an estate could not recover a six-figure "Title 26 miscellaneous offshore penalty" (MOP) the decedent paid to the Internal...more
9/1/2022
/ Audits ,
Breach of Contract ,
Foreign Bank Accounts ,
Income Taxes ,
IRS ,
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Remediation ,
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Self-Certification ,
Tax Penalties ,
Tax Returns ,
Willful Violations
Virtual currency transactions are now a prime focus of Internal Revenue Service (IRS) scrutiny. The IRS has numerous information-gathering tools to enforce its taxing power, including summons, artificial intelligence, data...more
12/4/2019
/ AICPA ,
Criminal Investigations ,
Cryptocurrency ,
Digital Currency ,
FBAR ,
Financial Transactions ,
FinCEN ,
Internal Revenue Code (IRC) ,
IRS ,
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Reporting Requirements ,
Suspicious Activity Reports (SARs) ,
Tax Planning ,
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Virtual Currency ,
Voluntary Disclosure