News & Analysis as of

FinCEN Internal Revenue Service Compliance

The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of... more +
The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -
Baker Botts L.L.P.

Taxpayer Assistance and Service Act – Tax Controversy Perspective

Baker Botts L.L.P. on

On January 30, 2025, a bipartisan group of US Senators released a discussion draft of the Taxpayer Assistance and Service Act (“TAS Act”), a legislative proposal that, if passed, could significantly alter tax controversy...more

ArentFox Schiff

What Private Companies and Family Offices Need to Consider in 2025

ArentFox Schiff on

Across all industries, private companies, family offices, and their owners and management teams face rapidly evolving challenges, opportunities, and risks in the dynamic environment that is 2025. Here are 11 issues that...more

Haynsworth Sinkler Boyd, P.A.

New Deadlines for FINCEN Compliance Issued

The Corporate Transparency Act (CTA) introduced substantial new reporting obligations for a wide array of corporate entities. Generally, any domestic entity formed by filing documents with a secretary of state or similar...more

Allen Barron, Inc.

International Business and Offshore Investment and Banking Create Genuine IRS Risk

Allen Barron, Inc. on

International business and offshore investment and banking create genuine risk and exposure with the IRS. This extends to real estate ownership outside of the U.S. and other offshore-related financial activities, which raise...more

Foodman CPAs & Advisors

NTA Addresses Overlap Reporting

On 1/8/25, the National Taxpayer Advocate (NTA) published its 2024 Annual Report to Congress and identified taxpayers’ problems and provided suggestions to further protect taxpayer rights and ease taxpayer burden. “By law,...more

Allen Barron, Inc.

A Foreign Trust Creates Complex IRS Reporting Requirements

Allen Barron, Inc. on

The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more

Allen Barron, Inc.

Foreign Corporate Ownership and Investments

Allen Barron, Inc. on

Are you involved in offshore or foreign corporate ownership and investments? Do you have real property, assets, or foreign bank or investment accounts? U.S. taxpayers with offshore business interests, holdings, investments,...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Final Regulations Applicable for Front-End Service Providers Facilitating Digital Asset and...

On December 30, 2024, the Department of the Treasury (the Treasury) and the Internal Revenue Service (the IRS) published the final regulations (Final DeFi Regulations) relating primarily to persons who are front-end service...more

Allen Barron, Inc.

What is Willful Blindness According to the IRS?

Allen Barron, Inc. on

What is willful blindness according to the IRS? How is this important in tax cases involving unreported or under-reported income, disclosure of offshore assets and income, FinCEN Form 114 (more commonly referred to as an...more

Smith Anderson

The Corporate Transparency Act: Extensions of Reporting Deadlines to Victims of Recent Natural Disasters

Smith Anderson on

As discussed in our four prior client alerts below, effective as of January 1, 2024, the Corporate Transparency Act (“CTA”) and rules issued thereunder by the Financial Crime Enforcement Network (“FinCEN”) require most U.S...more

Allen Barron, Inc.

Is it Too Late to Correct Past FBARs and File Amended Returns with the IRS?

Allen Barron, Inc. on

Is it too late to correct past FBARs and file amended returns with the IRS? The net is closing in on U.S. taxpayers with unreported or under-reported domestic and offshore income and assets. The IRS has increased audits in...more

Allen Barron, Inc.

The Statute of Limitations for an IRS Audit

Allen Barron, Inc. on

What is the statute of limitations for an IRS audit? What rules extend the window for an IRS audit? How long does the IRS usually have to complete an audit of your taxes? Everyone may have a little fear in the back of...more

Allen Barron, Inc.

IRS Updated Streamlined Filing Compliance Procedures

Allen Barron, Inc. on

What do you need to know about the IRS updated Streamlined Filing Compliance Procedures or "Streamlined Procedures?" Are you concerned about unreported or under-reported offshore income or assets? Are there accounts you...more

NAVEX

The Broader Significance of the DOJ Whistleblower Rewards Program

NAVEX on

The Department of Justice (DOJ) signaled it will soon join the list of government agencies to have implemented a whistleblower rewards program, putting further pressure on companies to have in place an effective compliance...more

ArentFox Schiff

Investigations Newsletter: Deputy Attorney General Monaco Warns Industries: “Fraud Using AI is Still Fraud”

ArentFox Schiff on

On March 7, Deputy Attorney General Lisa Monaco delivered the keynote remarks at the American Bar Association’s (ABA) 39th National Institute on White Collar Crime. She noted that artificial intelligence (AI) “holds great...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

DOJ Official Cites Old West ‘WANTED’ Posters in Announcement of New Whistleblower Monetary Awards Program

On March 7, 2024, Deputy Attorney General Lisa Monaco said that the U.S. Department of Justice (DOJ) will test out a program to pay whistleblowers if they provide information on serious financial crimes and foreign and...more

Allen Barron, Inc.

How Does the IRS Use AI to Identify Tax Cheats?

Allen Barron, Inc. on

Could Artificial Intelligence (AI) increase the likelihood of an IRS audit in your future? How does the IRS use AI to identify US taxpayers who attempt to hide assets, under-report income or otherwise cheat the IRS? In...more

ArentFox Schiff

Investigations Newsletter: Binance to Pay Historic $4 Billion Fine

ArentFox Schiff on

Binance to Pay Historic $4 Billion Fine - Binance Holdings Limited, the operator of the world’s largest cryptocurrency exchange, agreed to pay $4.3 billion to resolve allegations that it violated the Bank Secrecy Act (BSA)...more

Allen Barron, Inc.

Are There Strategies to Avoid an IRS Audit?

Allen Barron, Inc. on

Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to...more

Allen Barron, Inc.

Estate and Tax Planning for US Expatriates

Allen Barron, Inc. on

What are the most important elements of estate and tax planning for US expatriates?  Are you planning to move out of the United States?  Are you a US taxpayer who lives and works outside of the country?  What are some of the...more

Womble Bond Dickinson

Is Your Real Estate Company Ready for the CTA? Here’s a “Get Started” Checklist.

Womble Bond Dickinson on

Starting January 1, 2024, certain U.S. and foreign entities (Reporting Companies) must report detailed information about the individuals that beneficially own or substantially control them (Beneficial Owners) to the U.S....more

Gould + Ratner LLP

Corporate Transparency Act Will Require New Layer of Compliance for Private Companies

Gould + Ratner LLP on

A vast number of private businesses will face new requirements on how – and whether – they report their beneficial ownership interests to the U.S. government, effective at the start of 2024. While the time for compliance...more

Freeman Law

A Summary of the IRS’ Streamlined Filing Compliance Procedures

Freeman Law on

The IRS’ streamlined filing procedures were first offered by the IRS on September 1, 2012. Since that time, the IRS has made several revisions. A current summary of the IRS’ Streamlined Filing Compliance Procedures is...more

The Volkov Law Group

DOJ Cryptocurrency Guidance Outlines Enforcement Partnerships (Part II of II)

The Volkov Law Group on

DOJ’s Cyber Digital Task Force’s report, “Cryptocurrency: An Enforcement Framework,” provides a comprehensive on the growing partnerships between DOJ and other offices within the executive branch....more

Snell & Wilmer

FinCEN, OFAC and the IRS Place Virtual Currencies Under a Real-World Regulatory Microscope

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The Financial Crimes Enforcement Network (“FinCEN”) and the Office of Foreign Assets Control (“OFAC”) have recently stepped up the pressure on virtual currency companies. Increased regulatory scrutiny has largely taken the...more

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