FBAR Willfulness Easier to Prove Under Recent Reyes Second Circuit Decision... [ read ]
Matthew L. Roberts examines the Second Circuit's recent decision in U.S. v. Reyes and its significance to IRS compliance options.
Fifth Circuit Rejects IRS "Passive Investor" Test for Limited Partners in Self-Employment Tax Case... [ read ]
Naveid P. Jahansouz examines the Fifth Circuit's rejection of the IRS's effort to restrict the limited partner exception to passive investors.
Memo to IRS-CI: Don't Forget to Tout Your Legal-Source Income Casework!... [ read ]
Joseph A. Rillotta takes a closer look at IRS Criminal Investigation's recently released "Top 10 Cases of 2025" and highlights the absence of any legal-source income tax evasion cases.
Just In Time for the Holidays, IRS Criminal Investigation Releases Its 2025 Top 10 Cases... [ read ]
Joel N. Crouch breaks down the IRS Criminal Investigation Division's newly released Top 10 cases of 2025, just in time for the holidays.
Recent FTC Complaint Shows Taxpayers were Victims of IRS Collection Scheme... [ read ]
Matthew L. Roberts explores a recent development with serious implications for taxpayers facing IRS collection activity: how scammers are exploiting public Notices of Federal Tax Lien.
The Grinch's Tax Issues: Why Even a Mountaintop Hermit Can't Escape the IRS... [ read ]
Joel N. Crouch takes a lighthearted look at what would happen if the Grinch ever found himself on the IRS's radar.
Changes to IRS Voluntary Disclosure Program are Coming... [ read ]
Jeffrey M. Glassman shares insights from the American Bar Association's 2025 Criminal Tax Fraud and Tax Controversy Conference, where IRS Criminal Investigation Chief Guy Ficco announced that changes to the IRS voluntary disclosure program are coming.
Does Santa Have Tax Problems? A Look at Kris Kringle's Potential IRS Nightmares... [ read ]
Joel N. Crouch takes a lighthearted look at what would happen if Santa Claus became a US taxpayer. From employment taxes for elves to millions of gift tax returns, it's a festive reminder that even the North Pole isn't safe from tax compliance.
Can the IRS Search My Emails? The Lesson from Mukhi... [ read ]
Matthew L. Roberts explores a question with big implications for taxpayers in litigation: can the IRS obtain your personal emails?
NCAA Transparency Advocate Accuses UCLA of Skirting IRS Rules on Tax Exemptions, NIL Payments... [ read ]
Joseph A. Rillotta examines allegations that UCLA used a tax-exempt charity to route NIL payments to football players, potentially circumventing rules on charitable deductions and giving the program an edge with NIL.
