February 9, 2017
What Does a Willful Failure to Report Offshore Accounts Really Mean?

What Does a Willful Failure to Report Offshore Accounts Mean?

On this blog, we have frequently discussed the willfulness standard as it relates to one’s duty to satisfy offshore account and asset disclosure obligations set forth […]
February 6, 2017
defendant with lawyer speaking to a judge in the courtroom trial

A Deliberate or Willful Blindness Jury Instruction Is Rarely a Good Sign for a Criminal Tax Defendant

Recently on the Federal Tax Crimes blog, the tax fraud case of Happy Asker was analyzed in the context of the willful blindness jury instruction given […]
January 25, 2016
Swiss Bank Program

Union Bancaire Privée Joins Swiss Bank Program

Although the new year typically brings resolutions that aim to change a past habit or behavior, the Department of Justice has no such desire to change. […]
November 13, 2015
FBAR Penalties

Reduced FBAR Penalties May Be Permitted Through IRS Guidance

Many individuals with undisclosed foreign accounts are justifiably concerned about their failure to comply with the annual obligation to file FBAR (Report of Foreign Bank and […]
September 22, 2015

Income Tax Attorney

Paying income taxes on the success you or your business have experienced is an individual’s contribution back to the United States and part of what makes […]
August 18, 2015

Disgraced Dentist Pleads Guilty to Tax Evasion

Dentists, doctors, lawyers, and accountants are generally professions that the general public looks to as well-regulated and respectable professionals. We often trust these individuals with our […]