Is My Case Criminal? Civil Fraud vs. Tax Evasion
This article examines the concept of willfulness in the context of international tax enforcement, focusing on the factors that can transform a... Read More
IRS Provides Guidance on FBAR Penalties
Tax professionals who advise clients on issues with FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR), should become familiar... Read More
A Guide to the IRS’ New Streamlined Offshore Compliance Program
On June 18, the IRS announced major changes to its offshore voluntary compliance programs, providing new options to help taxpayers residing both... Read More
Credit Suisse’s Impact on Its U.S. Clients
In the government’s criminal investigation and charging of Credit Suisse AG with helping U.S. taxpayers evade taxes, the IRS used a new... Read More
The Modification and Compromise of Restitution Orders in Criminal Tax Cases
Mr. Walker was invited to Washington D.C. by the Taxation Section, State Bar of California, to present a position paper regarding The... Read More
Can a Taxpayer Refuse an IRS Summons?
During the course of an IRS investigation, the IRS has the authority to issue an administrative summons seeking records and testimony (Sec.... Read More
Department of Justice’s Swiss Bank Program May Put Some U.S. Taxpayers At Risk
On Aug. 29, 2013, the U.S. Department of Justice (DOJ) and the Swiss Federal Department of Finance signed a joint statement aimed... Read More
IRS Changes Policy, Relaxes Rules for Innocent Spouse Relief
A recent revenue procedure and chief counsel notice reflect significant IRS policy and procedural changes for claims under section 6015(f). The IRS... Read More
A Proposed Voluntary Disclosure Program for the California Franchise Tax Board
This paper provides a framework for discussing the implementation of a voluntary disclosure program for individuals and businesses with the California Franchise... Read More
IRS will not let investors off the hook in overvaluing assets
Individuals should exercise prudence in evaluating transactions designed to generate paper losses on federal income tax returns—so-called tax shelters. Taxpayers should focus... Read More
