A Good Lickin'
The Presumption of Innocence Podcast: Episode 60 - Enforcement Priorities of the Second Trump Administration: Employee Retention Tax Credit
The Presumption of Innocence Podcast: Episode 58 - Enforcement Priorities of the Second Trump Administration: IRS Investigations
Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
UK corporate offence of failure to prevent tax evasion
The Panama Papers - What the Fallout Means for U.S. Companies and Professionals
Foreign Bank Account Reporting and Employment Tax Enforcement: Ronn Owens interviews Steve Moskowitz
The Panama Papers & The Tempo of International Corruption Cases
Lauryn Hill's Tax Evasion a 'Battle for Survival': Lawyer
How many U.S. taxpayers and expatriates may need to file offshore disclosures and FBARs with the IRS? Should those who have not yet filed a disclosure application utilize the VDP (Voluntary Disclosure Program) or a...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
On Monday, July 8, 2024, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released additional FAQs specifying that a reporting company (i.e., a company to which no exemption applies) created or...more
The recently implemented Corporate Transparency Act (the “CTA”) requires that certain entities report information about themselves and their “beneficial ownership” to the Financial Crimes Enforcement Network of the United...more
Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more
Since the Corporate Transparency Act took effect on January 1, 2024, scammers have seized the opportunity to send notices to owners of recently formed companies offering “filing services.” In response to these scams, FinCEN...more
On March 1, 2024, Judge Liles C. Burke of the Northern District of Alabama, Northeastern Division, ruled in U.S. v. Yellen that the Corporate Transparency Act (the “Act”) is unconstitutional. The federal district court found...more
On March 1, 2024, the U.S. District Court for the Northern District of Alabama ruled that the Corporate Transparency Act (“CTA”) is unconstitutional. The CTA requires many U.S. entities to disclose their individual beneficial...more
On March 1, 2024, the United States District Court for the Northern District of Alabama ruled that the Corporate Transparency Act (CTA) exceeds the constitutional limits on Congress’s legislative power and is therefore...more
On March 1, 2024, the U.S. District Court for the Northern District of Alabama in National Small Business United et al. v. Janet Yellen et. al., Case No. 5:22-cv-1448-LCB, held the Corporate Transparency Act (the “CTA”) to...more
Effective January 1, 2024, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) will require certain newly formed and pre-existing entities to submit information regarding their beneficial owners...more
The Corporate Transparency Act (CTA) will affect most small, privately held businesses starting January 1, 2024. Does the CTA apply to you? What is the CTA? The CTA, a law enacted by Congress, will require certain business...more
The U.S. government just averted a government shutdown this past Saturday (or at least punted for another 45 days). In the last three weeks all signals from the Financial Crimes Enforcement Network (“FinCEN”) suggests the...more
The Corporate Transparency Act (CTA) was enacted to enhance corporate transparency and combat illicit activities such as money laundering and tax evasion. While the primary focus of the CTA is unearthing those involved in...more
On January 1, 2021, Congress enacted the Corporate Transparency Act (the “CTA”) as part of the Anti-Money Laundering Act of 2020 in the National Defense Authorization Act for Fiscal Year 2021. Congress passed the CTA to...more
We have all heard the stories. Romeo and Juliet, Cleopatra and Mark Antony, and my personal favorite, Illsa Lund and Rick Blaine. Everyone loves a great love story. A developing romance leading to an emotionally pleasing and...more
U.S. Taxpayers (includes a citizen, permanent resident, corporation, partnership, limited liability company, trust and estate) are required to file a Report of Foreign Bank and Financial Accounts (FBAR) if they have...more
Depending upon how foreign real estate is owned and/or controlled, a number of different tax reporting regimes may be implicated. Each of these has its own corresponding penalties and generally applies to United States...more
On November 29, 2018, the Internal Revenue Service (the "IRS") published a memorandum (the "Memorandum") dated November 20, 2018, outlining the new process for all voluntary disclosures, both domestic and offshore (the "New...more
There are legal and financial consequences to any U.S. person who underreports their income. Moreover, similar consequences may exist even in a situation in which all income is reported, yet certain information returns are...more
On March 13th, the Internal Revenue Service ("IRS") announced that the offshore voluntary disclosure program ("OVDP"), which was first launched in 2009 and modified several times, will close to new taxpayers after September...more
As the world now knows, an indictment against Paul Manafort, Jr., a former campaign chairperson for now-President Donald Trump, and Manafort’s associate, Richard Gates III, was unsealed yesterday. ...more
Under the dark cover of the Panama Papers scandal, FinCEN moved quickly to issue its beneficial; ownership regulations. For all of the US regulatory and financial industry bluster, it is about time. The United States stands...more
On May 10, 2016, the Treasury Department issued proposed regulations that, if approved, will require business entities formed in the United States that are owned by a single foreign person to obtain an employer identification...more
A new Financial Crimes Enforcement Network (FinCEN) rule under the Bank Secrecy Act will require institutions to more specifically identify legal entity customers and increase anti-money laundering diligence. The rule will...more