Our Blog

Third Circuit Throws a Curve Ball on FBAR Penalties by Robert S. Horwitz

In Bedrosian v United States the plaintiff paid 1% of a $975,789 FBAR penalty.  Not disputing jurisdiction, the Government counterclaimed for the unpaid balance with interest.  The district court held that Bedrosian was not liable for a willful FBAR penalty, even though he had known about the FBAR filing requirement.  The Government appealed to the Third Circuit. […] Read More…

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Tax Court Determines that for Federal Estate Tax Purposes, an Assignee Interest Is a Partnership Interest by Robert S. Horwitz

The Tax Court in Estate of Streightoff v. Commissioner, T.C. Memo 2018-178, here, faced two issues: whether an interest in a family limited partnership was an assignee interest and what discount should be applied.  Holding for the Commissioner, it determined that the interest was a partnership interest and not an assignee interest.  And since the expert for […] Read More…

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MICHEL STEIN to Speak on How to Persuade: Tips on Trial Practice Techniques at the Upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy

We are pleased to announce that Michel Stein will be speaking on How to Persuade: Tips on Trial Practice Techniques at the upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy, at the Las Vegas Encore Wynn, Friday, December 14, 2018 from 11:30 a.m. to 12:30 p.m. Find […] Read More…

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IRS Updates Its Voluntary Disclosure Program to Include Foreign and Domestic Disclosures by Taxpayers with Potential Criminal Liability by Robert S. Horwitz

On November 20, 2018, the IRS rolled out its new updated procedures for taxpayers who wish to make voluntary disclosures.  The notice emphasizes that the voluntary disclosure procedures are designed for taxpayers who could face potential criminal prosecution.  Taxpayers who do not face potential criminal prosecution but failed to report all income from foreign sources […] Read More…

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STEVEN TOSCHER and MICHEL STEIN to Speak on Taxpayer Residency at an Upcoming Strafford Webinar

Steven Toscher and Michel Stein will be speaking at an upcoming presentation of the Strafford webinar Taxpayer Residency: New IRS Examination Guidance, Navigating Federal and State Tax Residency Rules scheduled for Tuesday, December 18th, 10:00 a.m. to 11:50 a.m. PST/1:00 p.m. to 2:50 p.m. EST. This webinar will guide tax professionals and advisers on recent […] Read More…

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Tax Notes – When Noncompliance With FATCA Is More Than a Civil Tax Matter by SANDRA BROWN

In this article, Sandra Brown examines the government’s use of 18 U.S.C. section 371 to charge related criminal violations under the Foreign Account Tax Compliance Act. Following on the heels of the Justice Department’s expanded use of the federal statutory reporting obligations that require some U.S. persons to disclose their offshore bank accounts by filing […] Read More…

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MICHEL STEIN Will Participate In The Panel Titled “Cryptocurrency: What Every Practitioner Needs to Know” at the 2018 New England IRS Representation Conference

We are pleased to announce that Michel Stein will be participating at an upcoming panel at the 2018 New England IRS Representation Conference on Friday, November 30th from 1:45 p.m. to 2:45 p.m. The presentation will provide tax professionals with a critical first look at new IRS initiatives on taxpayer compliance and reporting obligations for […] Read More…

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EDWARD ROBBINS, JR., to Speak on Ethical Challenges in Tax Practice at the Upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy

We are pleased to announce that Edward Robbins, Jr. will be speaking on Wisdom Across the Generations: How to Address Ethical Challenges in Tax Practice at the upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy, at the Las Vegas Encore Wynn, Thursday, December 13, 2018 from 2:15 […] Read More…

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DENNIS PEREZ to Speak at the Upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy

We are pleased to announce that Dennis Perez will speak on Ethical and Other Issues When Representing Non-Compliant Taxpayers: Domestic and Foreign Voluntary Disclosures In a Post-Program World at the upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy, at the Las Vegas Encore Wynn, Friday, December 14, […] Read More…

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ROBERT HORWITZ to Speak at The Knowledge Group Overcoming FBAR Penalties: Best Practices and Practical Tips Webinar

We are pleased to announce that Robert Horwitz will be speaking at an upcoming webinar on Overcoming FBAR Penalties: Best Practices and Practical Tips, January 17, 2019, 9:00 a.m. to 11:00 a.m. (PST)/12:00 p.m. – 2:00 p.m. (ET). Over the years, the Internal Revenue Service (IRS) has enforced drastic penalties for inaccurate, late, and non-filing […] Read More…

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SANDRA BROWN, Speaker on Criminal Trial Practice at the Upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy

We are pleased to announce that Sandra Brown will be speaking on Criminal Trial Practice/Ask the Experts at the upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy, at the Las Vegas Encore Wynn, Thursday, December 14, 2018 from 1:30 p.m. to 3:00 p.m. The most difficult topics […] Read More…

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SANDRA BROWN, Co-Moderator at the Upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy

We are pleased to announce that Sandra Brown will be Co-Moderator of the Criminal Tax Workshop at the upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy, at the Las Vegas Encore Wynn, Thursday, December 13, 2018 from 9:30 a.m. to 12:00 p.m. Taxpayers can become aware they […] Read More…

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