March 25, 2014

International tax investigations are an IRS high priority

International tax compliance is currently a top priority of the IRS. The IRS perceives a pattern of abuse where U.S. Taxpayers use offshore accounts, entities and […]
March 25, 2014

Who collects restitution and penalties?

The U.S. Attorney General is responsible for collection of an unpaid fine or restitution under the authority of 18 U.S.C. §3612(c). However, there are several options […]
March 25, 2014

Recent international tax and reporting prosecutions

Igor Purlantov, a New York attorney, pleaded guilty and was sentenced to 24 months in prison for fraudulently transferring more than $1 million from the bank […]
March 25, 2014

Precautions to be taken in the pre-audit phase

The most important part of any pre-audit strategy is due diligence, which typically means identifying potential examination and litigation risks in actual and planned transactions. Steps […]
March 25, 2014

Statute of Limitations raised during a FBAR audit?

The IRS generally has six years after “the transaction with respect to which the penalty is assessed” to impose a civil penalty related to an FBAR […]