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Category: Hot Topics

Important BREAKING News for US Taxpayers and Foreign Bank Accounts: US Supreme Court Rules in Favor of the Taxpayer in Regard to FBAR Filings!

Hot Topics

Posted in on September 1, 2023

The United States Supreme Court has recently ruled in favor of taxpayers in a significant case involving Foreign Bank Account Reporting (FBAR) requirements. The ruling addresses the penalty structure for non-willful violations of FBAR reporting obligations, emphasizing a per-report basis. This decision carries substantial implications for taxpayers and underscores the critical need for individuals facing FBAR-related challenges to secure the services of an experienced Washington DC tax attorney.

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The IRS is Targeting Tax-Free Distributions Under Maltese Pension Plans

Hot Topics, Offshore Account Update

Posted in on August 11, 2023

In 2011, the U.S.-Malta Tax Treaty started a gold rush of sorts. The treaty’s language arguably (and unintentionally) allowed U.S. taxpayers to open personal retirement plans in Malta, contribute appreciated assets, and then systematically take structured distributions without incurring federal tax liability on the plan’s interest or principal. This led to many taxpayers opening Maltese pension plans—with some avoiding tens of millions of dollars in federal income tax liability.Read More

IRS: Businesses that Claim the ERC Credit Are Under the Microscope

Hot Topics, News, Offshore Account Update

Posted in on March 17, 2023

The Internal Revenue Service (IRS) recently announced that it is continuing to target businesses that have claimed the Employee Retention Credit (ERC). The ERC was a limited-time credit offered to qualifying businesses under the CARES Act for the 2020 and 2021 tax years. According to an IRS News Release, the agency has identified widespread fraud related to the ERC, and, as a result, it is “actively auditing and conducting criminal investigations related to these false claims.”Read More

BBA Partnership Audits and the IRS’ Centralized Partnership Audit Regime: What Business Partners Need to Know in 2022

Hot Topics, Offshore Account Update

Posted in on June 16, 2022

Among the Internal Revenue Service’s (IRS) many priorities is enforcing partnerships’ federal income tax obligations. In recent years, the IRS has implemented two major programs focused specifically on partnership tax enforcement, and we expect to see increased activity under both of these programs in 2022 and beyond. In this article, Washington D.C. federal tax attorney Kevin E. Thorn, Managing Partner of Thorn Law Group, discusses some of the implications of these recent developments for business partners:Read More

IRS CI is Targeting Cryptocurrency Cases Involving Fraud and Other Crimes

Hot Topics, Offshore Account Update

Posted in on January 21, 2022

Cryptocurrency enforcement has become a major priority for the Internal Revenue Service’s Criminal Investigations Division (IRS CI). The division seized $3.5 billion in cryptocurrency in 2021, which accounted for 93 percent of all seizures for the year. Although IRS CI is targeting individuals and organizations for tax crimes in some of these cases, it is pursuing other charges as well. Washington D.C. tax lawyer Kevin E. Thorn, Managing Partner of Thorn Law Group, explains.Read More

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"Kevin E. Thorn and the tax attorneys at Thorn Law Group are exceptional. When I came to them, I had just received a letter from the Department of Justice concerning an undisclosed bank account at a Swiss bank. I thought I was going to go to jail and lose everything I had worked for just because my family and my business are international. Mr. Thorn's knowledge of the tax laws and his skills in presenting my situation to the IRS and Department of Justice proved superior!"
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