On June 30, 2023 the District Court in the Northern District of California granted a petition to enforce the cryptocurrency exchange Kraken to release customer information. Specifically, Kraken was ordered to produce the...more
11/6/2023
/ Crypto Exchanges ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
Financial Markets ,
Financial Regulatory Reform ,
Financial Services Industry ,
Financial Transactions ,
FinTech ,
Income Taxes ,
Investment ,
IRS ,
Reporting Requirements ,
Tax Liability
On June 21, 2022, the United States Supreme Court agreed to hear a dispute involving split decisions among the circuit courts on non-willful penalties. The Fifth Circuit parted ways with the taxpayer friendly decision of the...more
6/23/2022
/ Failure-to-File ,
FBAR ,
Foreign Financial Accounts ,
Income Taxes ,
IRS ,
Penalty Reductions ,
Regulatory Violations ,
Reporting Requirements ,
Tax Court ,
Tax Evasion ,
Tax Penalties ,
Tax Planning
On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account...more
12/1/2021
/ Enforcement Actions ,
FBAR ,
Foreign Bank Accounts ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Offshore Funds ,
OVDP ,
Reporting Requirements ,
Tax Court ,
Tax Evasion ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Tax Returns
The IRS has several tools in its arsenal to encourage compliance and audit and enforce those it believes are failing to comply. One of the most powerful tools is the John Doe summons. A regular IRS summons seeks information...more
5/6/2021
/ Bitcoin ,
Capital Gains ,
Coinbase ,
Crypto Exchanges ,
Cryptocurrency ,
Income Taxes ,
Investors ,
IRS ,
John Doe Investigation ,
Reporting Requirements ,
Virtual Currency
Cryptocurrency is more accessible than ever before. Banks are continuing to both implement procedures for and, in some cases, develop their own cryptocurrencies. Paypal allows users in the U.S. to buy, sell and hold select...more
1/29/2021
/ Bitcoin ,
Capital Gains ,
Cryptocurrency ,
Digital Currency ,
Financial Transactions ,
Income Taxes ,
Investment ,
IRS ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Virtual Currency ,
Voluntary Disclosure