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Articles Posted in Tax Litigation and Tax Controversy

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FATCA Obligation? IRS’ International Data Exchange Service Again Ratchets up Risk of Undisclosed Foreign Account Detection

Since FATCA’s passage, critics of the law have assailed its provisions and the IRS’ interpretations of the law. However one of the most oft-repeated charges against the account disclosure statute was that the IRS, itself, was not ready for the law and could not handle the influx of data including…

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Attempts to Conceal Your Tax Mistakes Compounds Your Tax Problems Increasing the Risk of a Prison Sentence

Nobody wants to file and pay taxes. However, the only thing worse than filing and paying taxes each year may be making a filing mistake that opens one up to an IRS tax audit or a criminal tax prosecution. Many times taxpayers may realize that they made an error on…

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Failure to File Taxes Plus a Frivolous Tax Argument Can Equal a Prison Sentence

The Wisconsin owner of several self-help and life development companies received a rather jarring wake-up call when he was convicted on tax crimes and sentenced to a year in federal prison. Eric T. Plantenberg had failed to file taxes for ten years from 2000 to 2010 after he began subscribing…

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Beware of the Unexpected Tax Refund Windfall & Other Pitfalls

Each and every year April 15th brings fear and dread for millions of Americans who fear that they will face a hefty tax liability. Some may even choose to put off the filing by requesting an extension prior to the filing deadline, but the fact remains that the tax will…

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Four Family Members Who Defrauded IRS of more than $5 million in Payroll Tax Payments Face Prison

Temporary employment agencies have become a more prevalent part of the American work experience since the 2007 financial crisis and the difficult economic times that followed. While on one hand, temporary employment agencies can provide workers with an entry point into a new industry, on the other hand they require…

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Rushing through Your Taxes Can Increase the Odds of an IRS Audit

It is not uncommon for many people to want to get done with their taxes as quickly as possible and not devote a moment beyond what they have to. If they complete their own taxes using computer software or an online program, they may rush through the process and fail…

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OVDP can correct FBAR disclosure problems

In the past, having an interest in or signature authority over a foreign financial account did not attract the level of attention and scrutiny that it does today. This is because in the past foreign banking secrecy laws prevented even the disclosure of the identity of the account holder or…

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What are the top signs a criminal tax investigation is forthcoming?

While many people think that a criminal tax situation is something that cannot happen to them unless they had the intent to defraud the government, the truth is that criminal tax charges can be triggered by even a slight misstep. Mistakes on your taxes that are perceived as willful misstatements…

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More than 100 International Agreements Mean the Risk of Undisclosed Foreign Account Detection is Higher Than Ever

At one point, banking secrecy laws in traditional tax havens were considered to provide ample protections in concealing the identity of the account holder. Wealthy individuals, companies, partnerships and a variety of other entities utilized these secrecy laws to open accounts where millions of dollars of otherwise taxable income could…

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Filing Taxes Each and Every Year is Essential

If you were to ask people about the things that they should do every single year, they are likely to mention visiting the doctor for a physical, taking their car in for preventative maintenance, and maybe even a tradition that the person spearheads every year. It is unlikely, however, the…

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