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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)....

Surprising IRS Tax Bracket Changes for 2025

Have you come across the surprising IRS tax bracket changes for 2025?  Yesterday, the IRS released the 2025 income tax brackets for U.S. taxpayers.  The inflation adjustments to tax brackets were a pandemic-boosted 7% for 2023 and 5.4% for this year's 2024 brackets.  However, the annual increase in IRS tax...

The Action Cryptocurrency Investors Need to Take Immediately

What is the action cryptocurrency investors need to take immediately?  What has changed, and why should any digital asset holder or investor pay attention to this game-changing development? Here is the short answer: If you don’t take action, you will pay substantially more tax than you otherwise should on every...