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,
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
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.
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
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
The IRS closely monitors cash transactions to ensure businesses across all industries comply with tax laws. Cannabis businesses, often reliant on cash, face particular scrutiny. A recent IRS memo provides important insights into how the
International tax reporting requirements are complex, and the penalties for non-compliance can be severe. In Mukhi v. Commissioner of Internal Revenue, the U.S. Tax Court considered a case involving a taxpayer who faced both criminal
Some businesses that claimed the employee retention credit (ERC) have begun receiving IRS letters telling them their claims are on hold because they are under audit and must provide additional information to the agency. Several
The Internal Revenue Service announced in March that its compliance efforts related to the Employee Retention Credit had exceeded $1 billion. The agency specified that “more than 12,000 entities filed over 22,000 claims that were
The Employee Retention Credit (ERC) offered financial relief to businesses struggling due to COVID-19. However, many ineligible applicants filed claims, or requested excessive amounts, often misled by aggressive marketing tactics. IRS Crackdown The IRS is
Recent funding increases through the Inflation Reduction Act (IRA) have revitalized the IRS’s enforcement capabilities. A new campaign signals this shift, targeting high-income taxpayers who failed to file federal income tax returns. This initiative represents
The Internal Revenue Service (IRS) places significant emphasis on the role of Bank Secrecy Act (BSA) filings in supporting the work of its Criminal Investigations (CI) division. Their recent report indicates that an impressive 88%
