Handling Audits of Delinquent International Information Returns
This article examines strategies for handling an IRS investigation of international returns, and recommends ways to improve audits, foster taxpayer compliance, and... Read More
Is Your Client the Subject of an FBAR Examination?
Has a client received a letter from the IRS asking to schedule an appointment to examine the client’s compliance with the requirement... Read More
Income Taxation of Trusts in California
Recently, in a closely watched case, the California Superior Court in San Francisco rejected the Franchise Tax Board’s long-standing approach to the... Read More
IRS Closer to Obtaining Virtual Currency Records
On Nov. 30, 2017, after a lengthy summons enforcement proceeding, a federal district court issued an order granting in part and denying... Read More
IRS New Compliance Campaigns and International Audits of Individuals
On November 3, 2017, the IRS announced the roll out of 11 Large Business and International (LB&I) Compliance Campaigns.LB&I previously announced the... Read More
Form W-9 or W8-BEN? How to Classify a Dual Resident Taxpayer
Mr. Walker was invited to Washington D.C. by the Taxation Section, State Bar of California, to present a position paper regarding how... Read More
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
