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THAI RESIDENTS MUST NOW PAY THAI INCOME TAX ON FOREIGN SOURCE INCOME

The Thai Revenue Department recently issued Order No. 16/2023 (the “Order”), which marks a significant shift in Thai tax policy as it relates to Thai Residents, who derive income from foreign sources or own offshore assets. The Order, which…
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LARGE TAX REFUNDS AND THE GHOST PREPARER

Earlier this year a Charlotte man was charged with tax fraud in a 20 count criminal indictment, charging him with aiding and assisting in the preparation and filing of false returns over a five year period. According to the allegations, between…
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FBAR PROSECUTIONS-FORMER CFO SENTENCED TO EIGHTY SIX MONTHS IN PRISON

On September 21, 2023 a  former CFO of  a Russian natural gas company was sentenced to seven years in prison, ordered to pay $4 million dollars in restitution and an additional $350,000 in fines in connection with a number of tax and financial…

WHAT DO OFFERS IN COMPROMISE AND ALUMINUM SIDING HAVE IN COMMON?

After many years, I decided to watch Tin Men again. It is a 1987 movie starring Danny DeVito and Richard Dreyfuss, both of whom are aluminum siding salesman in Baltimore in the late sixties.  They run  multiple scams, including “Life Magazine”…

PROSECUTIONS FOR UNPAID EMPLOYMENT TAXES ON THE RISE

The assessment of the § 6672 penalty can be devastating, and in some cases, life changing. Individuals who are subject to the penalty usually state that they were unaware that failure to collect and pay employment taxes to the IRS could result…

FBAR PENALTY RELIEF FOR TAXPAYERS. NON-WILLFUL FBAR PENALTY IS TO BE ASSESSED PER FORM

On February 28, 2023, in Bittner v United States, 598 U.S. (2023) the U.S. Supreme Court, in a five to four decision, ruled that the non-willful FBAR penalty should be assessed per form rather than per account. The decision settles the inconsistent…

SUPREME COURT TO DECIDE WHETHER MANDATORY REPATRIATION TAX IS CONSTITUTIONAL WITH RESPECT TO CFC UNDISTRIBUTED INCOME

On June 26, 2023 the Supreme Court granted the Petitioners’ Application for a Writ of Certiorari for purposes of considering the constitutionality of the Mandatory Repatriation Tax as it pertains to U.S. Shareholders in a Controlled Foreign…

ARE EMPLOYMENT TAX EXAMINATIONS BEING USED AS A PRETEXT FOR CRIMINAL PROSECUTION? 2022 ROUND UP

  Prosecution for employment tax crimes in 2022, reflects an increase in investigations for employment tax violations by the Department of Justice, Tax Division and also provides some insight as to the Government’s intention to prioritize…

FINAL RULE ISSUED UNDER THE CORPORATE TRANSPARENCY ACT – IMPLICATIONS FOR THE SMALL BUSINESS OWNER

The U.S. Department of the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) recently issued its Final Rule under the Corporate Transparency Act (CTA) implementing the CTA’s requirements related to reporting beneficial…
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AUDIT RISK TO INCREASE FOR LOW TO MIDDLE INCOME TAXPAYERS UNDER THE INFLATION REDUCTION ACT

The IRS estimates that individual taxpayers underreported their income tax on average by $245 billion each year for tax years 2011 to 2013 (See IRS Publication 1415). This underreporting is the largest component of the tax gap—the difference…