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What is Willful Blindness According to the IRS?

What is willful blindness according to the IRS?  How is this important in tax cases involving unreported or under-reported income, disclosure of offshore assets and income, FinCEN Form 114 (more commonly referred to as an "FBAR"), and even digital currencies and Non-Fungible Tokens (NFTs)? In an internal IRS memorandum from...

Integrative Legal, Tax, Accounting, and Business Advisory Services More Important Than Ever

Integrative legal, tax, accounting, and business advisory services are more critical than ever as we address the challenging environment of continuous change.  Seek change; wherever you find it, opportunity will exist. The speed of business has rapidly accelerated in recent years, and the ability to resolve problems and take prompt...

A New Wave of U.S. Expatriate Income Tax Refunds?…

Is a new wave of U.S. expatriate income tax refund applications on the table?  The answer to this question hangs in the balance as we await an appeal on the question of whether or not specific Foreign Tax Credits can be applied to offset the Net Investment Income Tax (NIIT)....