The Foreign Gift Penalty Trap
The IRS’s Inflexible Stance Discourages Good Faith Compliance The requirement for U.S. persons to report large foreign gifts via Form 3520 is well-known, as is the steep penalty for failure to file: the greater of
Parag Patel Esq. speaker at the National Association of Enrolled Agents (NAEA) Seminar “2025 Mid-Year Update”
Parag Patel Esq. was the featured speaker at the National Association of Enrolled Agents (NAEA) Seminar “2025 Mid-Year Update” last month to over 500 tax professionals. Seminar description is below: “2025 Mid-Year Update” The informative
The Complex Landscape of FBAR and Foreign Asset Reporting: A Critical Webinar Update for Tax Professionals (Free)
The global financial landscape is constantly shifting, presenting U.S. taxpayers and their professional advisors with a complex web of compliance challenges. For those managing clients with foreign assets, the obligations are particularly stringent, with potential
The Department of Justice’s Focus on Employment Tax Crimes
Despite staffing cuts, the Department of Justice (DOJ) continues to demonstrate its aggressive stance on employment tax evasion, with several significant prosecutions and sentencings announced in the past two months. For tax professionals, these cases
Dr. Sriram Case: A Summary of Key Tax and Legal Issues
A recent case serves as a clear illustration of the serious consequences that can result from tax and financial non-compliance, particularly for high-net-worth individuals with foreign assets. The case, which involved a combination of tax
All Things Appeals Webinar: A Strategic Guide for Tax Professionals
For tax professionals, successfully navigating the IRS appeals process is a critical skill that can profoundly impact a client’s outcome. It requires a deep understanding of not only tax law but also the procedural and
Navigating IRS Staffing Changes: Best Practices for Tax Pros
The operational landscape of the IRS has shifted dramatically in recent months, with a significant reduction in its workforce. This change, driven by broader government-wide initiatives, presents a new set of challenges for tax professionals.
IRS Appeals Case Memoranda: A Step Toward Greater Transparency
The IRS Independent Office of Appeals, often seen as a crucial last stop for resolving tax disputes before litigation, is taking a significant step toward greater transparency. A blog post by the National Taxpayer Advocate
New Jersey Aligns with Federal Law, Offers QSBS Exclusion for Gross Income Tax Purposes
For tax professionals with New Jersey clients, a significant change is on the horizon. A new state law (P.L. 2025, Chapter 67 (A4455/S4503)), signed by Governor Phil Murphy on June 30, 2025, brings New Jersey’s
IRS Appeals and ADR: Improvements and Remaining Barriers
For tax professionals, the IRS Appeals Office’s Alternative Dispute Resolution (ADR) programs represent a critical pathway to resolving disputes more efficiently than through traditional, protracted litigation. A recent blog post by the National Taxpayer Advocate
Winners and Losers in the “One Big Beautiful Bill Act”: A Tax Lawyer’s Perspective
The “One Big Beautiful Bill Act,” the latest legislative achievement of the current Trump administration, brings major changes to the tax code and broader economic policy. Its impact spans a wide range of industries and
Primer on Form 8938: Statement of Specified Foreign Financial Assets
The IRS places heavy emphasis on Form 8938, the Statement of Specified Foreign Financial Assets mandated by FATCA, and noncompliance can lead to harsh penalties and extended audit exposure. This form is required when U.S. taxpayers