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Day: May 9, 2026

Defending the Cross-Border Client: Join Parag at the NJSEA Annual Conference This June

9 May, 2026

The boundary between civil tax non-compliance and criminal tax exposure has never been more porous. As the Internal Revenue Service aggressively expands its enforcement footprint utilizing advanced data analytics, practitioners must be prepared to handle

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Recent Posts

  • 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
  • The End of the IRS Delinquent FBAR Submission Procedures?: Still Available under IRM 4.26.16.3.11July 8, 2026

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