Resources

How does one FBAR return filing give rise to 13 penalties? Ask the federal district court of California, which recently upheld the IRS’ imposition of separate non-willful penalties against 13 foreign accounts disclosed on a...

Josh Ungerman was featured in Accounting Today’s article, “IRS Criminal Investigation Leveraging More Data Analytics” for his interview with IRS Criminal Investigation chief Don Fort at the 2018 NYU Tax...

Josh Ungerman was quoted in the Wall Street Journal article, “The $26 Million Question: What Happens if You Don’t File Your Taxes for a Decade?” This article discusses the penalties and interest that will...

Newly-Announced IRS Audit Campaigns Continue Trend of IRS Enforcement in the Areas of International and Captive Insurance The IRS Large Business and International (LB&I) division – which serves corporations, subchapter...

The IRS Private Letter Ruling: When 100% Tax Certainty (or 100% Tax Relief) is a Must A structured transaction with lots of zeros behind the dollar sign?   A fatal planning misstep discovered too little too...