Introduction Under the Bank Secrecy Act (BSA), U.S. persons must generally file annual information returns to report their foreign accounts. Known as FBARs, these returns provide the government with specifics concerning the...
Category: Blog
Fifth Circuit Rejects IRS “Passive Investor” Test for Limited Partners in Self-Employment Tax Case
January 20, 2026
In a significant win for taxpayers, the Fifth Circuit has reversed the Tax Court’s decision in Sirius Solutions LLLP v. Commissioner and held that a limited partner under state law is exempt from self-employment...
‘Twas two days before Christmas and all through the house, not a lawyer was blogging. Except for Joel Crouch. I’m writing today, in part, to give lift to a post that my partner put out just before the holiday. Mr....
Just In Time for the Holidays, IRS Criminal Investigation Releases Its 2025 Top 10 Cases
December 23, 2025
By Joel N. Crouch, Blog
Regular readers of this blog know my colleagues and I are big fans of David Letterman, especially his top 10 lists, see What Do The National Taxpayer Advocate and David Letterman Have In Common?, More Top 10 Tax...
Overview Notices of Federal Tax Lien (NFTLs) are public records and can be used by scammers. A recent Federal Trade Commission (FTC) complaint highlights how some individuals may use public NFTL filings to target taxpayers,...