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
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
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
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),
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
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
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,
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
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
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
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
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
