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Category: Planning for Tax Minimization

The $90 Million Red Flag: Concealment, Trust Funds, and the Peril of Undocumented Labor in the Padilla Indictment

21 November, 2025

The federal indictment of Lorena Padilla of Villa Park, California, and her co-defendants is not merely a case of employment tax delinquency. It is a definitive example of how the government targets sophisticated schemes involving

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Parag Patel, Esq. Presents “Latest Federal Tax Controversy Update” for NJCPA Membership+

13 November, 2025

Parag P. Patel, Esq. delivered a presentation today via a live webcast titled “Latest Federal Tax Controversy Update.” The session reviewed a discussion of the One Big Beautiful Bill Act (OBBB Act). (NJCPA). Additional highlights

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Parag Patel, Esq. Presents at New Jersey Society of Certified Public Accountants — “One Big Beautiful Bill”

11 November, 2025

Parag Patel delivers a presentation for the NJCPA Membership in Union County on Tuesday, November 18, 2025, titled “One Big Beautiful Bill”. The session focuses on the implications of the “One Big Beautiful Bill” legislation

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The Trust Fund Recovery Penalty in Focus: United States v. Flaim and the Unwavering Standard of “Willfulness”

7 November, 2025

The Trust Fund Recovery Penalty (TFRP), authorized under Internal Revenue Code (I.R.C.) § 6672, remains one of the IRS’s most potent collection tools, allowing the IRS to hold individuals personally liable for an employer’s failure

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₿ Reporting Digital Assets: Understanding the Basic Income Tax Rules for Cryptocurrency

4 November, 2025

The landscape of digital asset taxation continues to evolve, but the core principle established by the Internal Revenue Service (IRS) remains firm: cryptocurrency is treated as property, not currency, for Federal income tax purposes. This

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The End of an Era: The IRS Eliminates the Acknowledgement of the Facts IDR

31 October, 2025

In a long-awaited change that will bring relief to tax professionals, the Internal Revenue Service (IRS) has confirmed the elimination of the Acknowledgement of the Facts (AOF) Information Document Request (IDR). This procedural shift, detailed

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IRS Appeals Enhances Post Appeals Mediation (PAM) for Greater Taxpayer Leverage

25 October, 2025

The Internal Revenue Service (IRS) Independent Office of Appeals has initiated a significant two-year pilot program for Post Appeals Mediation (PAM), signaling a commitment to Alternative Dispute Resolution (ADR) and offering tax professionals new strategic

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The Foreign Gift Penalty Trap

14 October, 2025

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

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Parag Patel Esq. speaker at the National Association of Enrolled Agents (NAEA) Seminar “2025 Mid-Year Update”

1 September, 2025

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

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The Complex Landscape of FBAR and Foreign Asset Reporting: A Critical Webinar Update for Tax Professionals (Free)

31 August, 2025

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

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The Department of Justice’s Focus on Employment Tax Crimes

29 August, 2025

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

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Dr. Sriram Case: A Summary of Key Tax and Legal Issues

28 August, 2025

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

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Recent Posts

  • The Enforcement Surge: What the DOJ and IRS Campaign Means for Tax Professionals and Their ClientsOctober 17, 2026
  • 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

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