Under Internal Revenue Code (IRC) section 7216 and its concomitant regulations, a tax preparer must obtain the consent of a taxpayer before disclosing or using…
The Confidentiality of a Client’s Tax Return Information
Provisions Tax Preparers Must Remember
Internal Revenue Code (IRC) section 7216 and its lengthy regulations govern when a tax return preparer may disclose or use a taxpayer's tax return information…
IRS Form 3520, Penalties, and Whether to Make a Protective Filing
Information Reporting on Foreign Trusts and Gifts
Whether a taxpayer is required to file IRS Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts, is…
TPP | Civil Penalties for Willful Violations of FBAR Requirements
Will the Fifth Circuit Clarify the IRS’s Burden of Proof?
District courts and other authorities disagree on whether the IRS must prove willfulness by a preponderance of the evidence or by clear and convincing evidence…