There has been a potentially landscape-altering decision out of the Fifth Circuit Court of Appeals (Court) regarding Reports of Foreign Bank and Financial Account (FBAR) penalties. In United States v. Bittner, that Court has held that each failure to report a qualifying account is a separate violation. This is a significant split from the Ninth [...]
The United States Department of Treasury (the Treasury) issued “The American Families Plan Tax Compliance Agenda,” detailing how the current administration intends to tackle the ever-looming noncompliance issue. This report was a follow up to the April of 2021 American Families Plan that included proposals that the administration announced to increase tax compliance. The Treasury [...]
In January of 2018, the Internal Revenue Service (IRS) issued a press release advising delinquent taxpayers to negotiate reasonable alternatives to enforced collection action, or risk losing their passport. Please find more on that press release and the IRS’s initial approach to passport revocation here. Suffice to say, the initial process for passport revocation was [...]