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Publications

The Government’s New Stance That The Non-Willful Civil FBAR Penalty Applies To Every Account On An Untimely-Filed FBAR, Rather Than To The Single Untimely FBAR Form

By: Caroline Rule Journal of Tax Practice & Procedure Summer 2020 Edition Recent litigation has focused on the government’s new position that the $10,000 non-willful civil FBAR penalty applies per account listed on an non-willfully untimely-filed annual FBAR—a Report of Foreign Bank or Financial Accounts that must be filed

Deposit Insurance Offers a Safe Haven

By Sidney Kess and Julie Welch The CPA Journal June 2020 Good times or bad, it is vital for investors to hold cash reserves. Federal deposit insurance provides an extra layer of comfort, so it is vital for CPA advisors to know the rules and be

Foreign Asset Reporting And U.S. Territories

By Usman Mohammad The ABA Tax Times Vol. 39 No. 3 – Spring 2020 Puerto Rico, American Samoa, Guam, The United States Virgin Islands, The Northern Mariana Islands—these are all United States territories or possessions. Individuals born in these territories are deemed by law to be

Prosecuting PPP Fraud May Be Harder Than It Seems

By Christopher M. Ferguson Law.com May 12, 2020 Once the May 14 deadline for arguably undeserving recipients of PPP loans to return the funds “no questions asked” has passed, the government will no doubt seek to make examples of undeserving PPP loan recipients. For anyone following

Tax Controversies: Audits, Investigation, Trials

By: Robert S. Fink LexisNexis 39th Ed. 2020 The 39th edition of “Tax Controversies: Audits, Investigations, Trials” has been published and is available on Lexis-Nexis. Authored by Kostelanetz & Fink co-founder Robert S. Fink and the attorneys of Kostelanetz & Fink, Tax Controversies is the recognized guide to

First Look At The CARES Act’s Provisions For Tax Relief

By Sidney Kess The CPA Journal April 2020 The Coronavirus Aid, Relief, and Economic Security (CARES) Act (H.R. 748), signed into law on March 27, 2020, is a $2.2 trillion package enacted to help individuals and businesses get through the health and economic crisis triggered by

Focus On IRS Tax Fraud Enforcement

By Megan L. Brackney Tax Notes Federal April 27, 2020 Given that combating tax fraud is a top agency priority, it is a good time to review the law and procedures related to tax fraud. In this article, Megan Brackney discusses the ways the IRS identifies

Tax Updates Related To The Coronavirus

By Sidney Kess The CPA Journal April 2020 The coronavirus (COVID-19) pandemic has not only upended the economy; it has also been the catalyst for several tax changes. The Families First Coronavirus Response Act (H.R. 6201), which was signed into law on March 18, 2020, creates