IRS Criminal Investigations: A Serious Threat With Warning Signs

Criminal investigations are the most potent (and severe) tool in the IRS’s enforcement toolkit. While they are used in only a small fraction of cases, their consequences are very serious, potentially leading to personal, social, and financial ruin, professional license

Handling an Unexpected Visit from IRS Criminal Investigation: Guidance for Taxpayers and Advisors

Over the years, many people have come to our firm after being visited by the Criminal Investigation Division of the Internal Revenue Service (IRS-CI). In the event that agents from the Criminal Investigation Division of the Internal Revenue Service (IRS-CI)

US Supreme Court Upholds Constitutionality of Repatriation Tax: Key Takeaways for Foreign Corporations

The U.S. Supreme Court’s recent decision in Moore v. United States has definitively upheld the constitutionality of the repatriation tax, a one-time tax on accumulated foreign earnings of U.S. companies under the 2017 Tax Cuts and Jobs Act (TCJA). This

New NJ Law Makes it Easier to Transfer Motor Vehicle Ownership Upon Death

New Jersey motor vehicle owners can now simplify the transfer of their vehicle upon their death by designating a transfer on death (TOD) beneficiary. This new law change allows vehicles to bypass the often lengthy and complex probate process for

How to Respond or Contest an IRS Criminal Investigation Division (CID) Summons

To contest an IRS Criminal Investigation Division (CID) summons, you generally have a few options: While the most formal way to contest an IRS CID summons is through the court system, there might be a few non-court options to explore,

IRS Criminal Investigation Division Summonses: A Key Tool in Tax Crime Investigations

The IRS Criminal Investigation Division (CID) frequently uses summonses to gather evidence in tax crime investigations. These summonses, authorized by law, grant special agents broad authority to examine tax returns, assess liabilities, and investigate any offenses related to tax administration

Form 3520: A Comprehensive Guide to Navigating the Complexities of Foreign Gift Reporting Under the Latest 2024 Proposed Regulations

Receiving a gift from a foreign person or entity can be a joyous occasion, but it also carries significant tax implications that necessitate meticulous attention. In the United States, Form 3520 plays a crucial role in ensuring the proper reporting

Detailed Technical Comments and Recommendations to the IRS on Proposed Regulations for Form 3520 and Code Section 6039F (REG-108066-22)

The Internal Revenue Service’s (IRS) proposed regulations regarding Form 3520 and Code Section 6039F, as outlined in REG-108066-22, significantly change the reporting requirements for receiving foreign gifts. While the intent behind these regulations is laudable, several aspects warrant closer examination

Top Six Criminal Tax Questions Asked

We get many questions from clients (and their advisors) about criminal tax. So I have compiled the six questions that come up the most frequently. Frequently Asked Questions: Addressing IRS Criminal Investigations Q: What course of action is recommended if

IRS Issues New Proposed Regs on Information Reporting on Foreign Gifts

The reporting of foreign gifts and inheritances is a very complex part of international tax law.  Many of our clients have been hit with large penalties for late filing Forms 3520 to report foreign gifts. Although many of these laws

Form 5471 Penalties Upheld in Latest Court Ruling

The D.C. Circuit handed the IRS a big win last week, holding that the IRS could assess international information return penalties for the failure to file Forms 5471, “Information Return of U.S. Persons With Respect to Certain Foreign Corporations.” The

NJCPA Seminar “The Corporate Transparency Act: What You Need To Know”

Parag Patel Esq. is a speaker this week at a New Jersey Society of Certified Public Accountants (NJCPA) Seminar entitled “The Corporate Transparency Act: What You Need To Know”. You may email our office to receive the seminar materials. Seminar