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Month: December 2014

New IRS Subpoenae and IRS Data Mining Expected

26 December, 2014

Last week a federal judge approved the IRS issuing “John Doe” summonses requiring FedEx, DHL, UPS, and numerous other intermediaries to produce information about U.S. taxpayers who used Sovereign Management & Legal Ltd. for offshore

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News from the 2014 Criminal Fraud and Tax Controversy Conference

22 December, 2014

We just returned last week from attending the Criminal Fraud and Tax Controversy Conference in Las Vegas, sponsored by the American Bar Association Section of Taxation where many government officials were in attendance. Below are

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IRS Releases Training Documents on Offshore Voluntary Disclosure Program

2 December, 2014

last month the IRS released more than 6,500 pages from the Internal Revenue Service on the agency’s Offshore Voluntary Disclosure Program and how it trains its agents. The documents included material used in training IRS personnel in

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Recent Posts

  • The IRS Starts Using AI in Tax FunctionsNovember 27, 2025
  • The $90 Million Red Flag: Concealment, Trust Funds, and the Peril of Undocumented Labor in the Padilla IndictmentNovember 21, 2025
  • Parag Patel, Esq. Presents “Latest Federal Tax Controversy Update” for NJCPA Membership+November 13, 2025
  • Parag Patel, Esq. Presents at New Jersey Society of Certified Public Accountants — “One Big Beautiful Bill”November 11, 2025
  • The Trust Fund Recovery Penalty in Focus: United States v. Flaim and the Unwavering Standard of “Willfulness”November 7, 2025

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