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Tax Audits Compliance Penalties

Vinson & Elkins LLP

Civil Tax Fraud: Should 75 Percent Appear Too Small, Be Thankful the IRS Doesn’t Take It All

Vinson & Elkins LLP on

Mistakes happen, including when it comes to reporting and paying taxes. And for taxpayers and their advisors, those mistakes can lead to costly consequences, as the Internal Revenue Code (“Code”) allows the Internal Revenue...more

Holland & Knight LLP

Same Statute, Same Form, Different Penalties: Welcome to FBAR Litigation

Holland & Knight LLP on

The "Report of Foreign Bank and Financial Accounts" (FBAR) penalty has been the subject of much litigation. This Holland & Knight alert focuses on the non-willfulness element of 31 U.S.C. § 5321(a)(5)(B). Both the U.S. Court...more

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