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The Enforcement Surge: What the DOJ and IRS Campaign Means for Tax Professionals and Their Clients

17 October, 2026

The Department of Justice, the Internal Revenue Service, and IRS Criminal Investigation (IRS-CI) recently announced a major national tax enforcement surge resulting in over $490 million in tax fraud cases. This coordinated initiative signals a

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The High Price of Payroll Tax Non-Compliance: Lessons from United States v. Pitts

15 September, 2026

Employment tax enforcement remains one of the highest priorities for IRS Criminal Investigation (IRS-CI) and the US Department of Justice. Business owners who fail to remit trust fund taxes often view these funds as a

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FBAR Willfulness, Recklessness, and the Excessive Fines Defense: Key Takeaways from United States v. Rund

11 September, 2026

Foreign bank account reporting under 31 U.S.C. § 5314 continues to represent a high-stakes area of international tax controversy. Earlier this month, in United States v. Rund (4th Cir. Sept. 4, 2026), the Fourth Circuit

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FBAR Enforcement and Penalty Analysis: United States v. Niksich

5 September, 2026

Willful FBAR violations Foreign bank account reporting under 31 U.S.C. § 5314 remains one of the highest-risk compliance areas for taxpayers with foreign financial interests. In United States v. Niksich (11th Cir. June 4, 2026),

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Billions Offshore, Millions Missed: What TIGTA’s Report Means for FATCA Enforcement

2 September, 2026

A recent report by the Treasury Inspector General for Tax Administration (TIGTA) Report 2026-308-009, released on April 8, 2026 (Read the full report here) publicly highlights a glaring gap in the IRS’s enforcement of unreported

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Criminal Tax Enforcement Takes Center Stage: The National Fraud Enforcement Division Memorandum

21 August, 2026

Earlier this month, the US Department of Justice on August 13, 2026, issued a new memorandum that marks a major change in fraud prosecutions. By establishing the National Fraud Enforcement Division, the Department of Justice

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Navigating New Jersey Tobacco and Vapor Excise Tax Audits

11 August, 2026

This year we have seen a large increase in examination (audit) notices from the New Jersey Division of Taxation Excise Tax Branch. State auditors in the NJ Excise Tax Branch are actively examining distributors, wholesalers,

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Navigating the US Estate Portability Election: Strategic Timing and Compliance Procedures for Form 706

13 July, 2026

For tax professionals, securing the deceased spousal unused exclusion (DSUE) amount for a surviving spouse is a cornerstone of effective wealth preservation. This is particularly vital in light of recent statutory changes that have increased

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IRS Transitions from First Time Abatement to Automated Penalty Relief: Strategic Impacts for Tax Advisors

11 July, 2026

Starting this year, the Internal Revenue Service is transitioning from the manual First Time Abate (FTA) framework to a computerized infrastructure under the newly introduced Automatic Exemption from Penalty (AEP) program. For tax advisors managing

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Parag Patel to Present on IRS Foreign Asset Enforcement at the 2026 NATP Taxposium

9 July, 2026

As international asset transparency reaches an all-time high, the IRS has dramatically escalated its scrutiny of cross-border holdings. For tax professionals, keeping pace with the aggressive enforcement priorities of the Internal Revenue Service (IRS) is

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The End of the IRS Delinquent FBAR Submission Procedures?: Still Available under IRM 4.26.16.3.11

8 July, 2026

In federal tax controversy practice, managing the divergence between the IRS’s public-facing administrative declarations (website, FAQs, etc.) and its internal operational guidelines requires careful technical analysis. This distinction has become critical following the action of

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Parag Patel Speaks at 2026 NJCPA Convention: Navigating the High Stakes of Criminal Tax

3 July, 2026

The intersection of civil tax compliance and criminal tax exposure is one of the most perilous environments a client can face. As the IRS continues to ramp up its enforcement capabilities and refine its data-matching

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Recent Posts

  • The Enforcement Surge: What the DOJ and IRS Campaign Means for Tax Professionals and Their ClientsOctober 17, 2026
  • The High Price of Payroll Tax Non-Compliance: Lessons from United States v. PittsSeptember 15, 2026
  • FBAR Willfulness, Recklessness, and the Excessive Fines Defense: Key Takeaways from United States v. RundSeptember 11, 2026
  • FBAR Enforcement and Penalty Analysis: United States v. NiksichSeptember 5, 2026
  • Billions Offshore, Millions Missed: What TIGTA’s Report Means for FATCA EnforcementSeptember 2, 2026
  • Criminal Tax Enforcement Takes Center Stage: The National Fraud Enforcement Division MemorandumAugust 21, 2026
  • Navigating New Jersey Tobacco and Vapor Excise Tax AuditsAugust 11, 2026
  • Navigating the US Estate Portability Election: Strategic Timing and Compliance Procedures for Form 706July 13, 2026
  • IRS Transitions from First Time Abatement to Automated Penalty Relief: Strategic Impacts for Tax AdvisorsJuly 11, 2026
  • Parag Patel to Present on IRS Foreign Asset Enforcement at the 2026 NATP TaxposiumJuly 9, 2026

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