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Tag: Caroline Rule

The IRS Ramps Up Cryptocurrency Enforcement

By Caroline Rule and Daniel Q. Flesch The Journal of Tax Practice & Procedure Summer 2021 Issue At a Federal Bar Association conference in March of this year, Damon Rowe—Director of the Office of Fraud Enforcement at the IRS—announced a new initiative. Operation Hidden Treasure consists of a special joint-effort

Caroline Rule Participates In A Panel Entitled “Common Themes on the Common Interest Privilege in Deals and Disputes” For The National Association Of Women Lawyers

On June 17, 2021, Caroline Rule participates in a panel entitled “Common Themes on the Common Interest Privilege in Deals and Disputes” for the National Association of Women Lawyers. This program will address the scope and applicability of the common interest doctrine to communications among parties aligned in corporate transactions

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 by a U.S. person “who