Hot TopicsPosted 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.
Read MoreIn 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 MoreThe 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 MoreAmong 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 MoreCryptocurrency 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.
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