Tax Law News and Insights

Per-Account Or Per-Form Penalty?

Published: Jul 02, 2022
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Key Takeaways: The law regarding computation of FBAR penalties is unclear. The United States Supreme Court has agreed to hear a case to settle a conflict among the circuit courts. Until the Supreme Court case is decided, taxpayers should work to delay IRS settlement discussions unless the favorable Ninth Circuit...

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Tax Controversy 2022

Published: Jun 22, 2022
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In 2022, we foresee several trends and developments that will converge to substantially impact tax controversies in the United States. The COVID-19 pandemic will likely continue to change how US taxpayers, the Internal Revenue Service (IRS), and courts approach tax controversies. Modest increases to the IRS's funding – as well...

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How Do I Become A U.S. Taxpayer? Let Me Count The Days

Published: Jun 02, 2022
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What does it mean to be a U.S. income taxpayer? Very simply, it means that you are taxable on your worldwide income and gains, even if you don't live full-time in the U.S. Any U.S. citizen is likely already familiar with this concept (and if they weren't, perhaps they learned...

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