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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
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
The US Treasury reports that it is expecting the tax gap to rise to approximately $7 trillion over the course of the next decade if left unaddressed. In May 2021, the US Department of the Treasury issued the “THE AMERICAN...more
Taxpayers should take prompt action to assess their situation, yet move carefully before making representations or filings to the IRS. Over the past month, the Internal Revenue Service (IRS) has sent letters to over ten...more