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,
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 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
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
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
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
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
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
