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How Does the IRS Define Willfulness in Unreported or Under-reported Offshore Income?

How does the IRS define willfulness in unreported or under-reported offshore income?  What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct?  Why should U.S. taxpayers be concerned whether the IRS perceives their actions as willful?  If you have accounts with any Foreign Financial Institutions...

Selling items Online? Is the IRS Watching?

Are you selling items online or receiving payment for goods and/or services on platforms such as PayPal, Venmo, eBay, Zelle, Etsy, or Cash App?  Online platforms are the preferred method of shopping for most Americans.  These platforms also support the gig economy and, what has to date been, the potential...

What is the “Abusive Use of Partnerships” and Why does the IRS Care?

What is now considered as the “abusive use of partnerships,” and why would this matter to the IRS?  The agency recently released IR-2024-166, which is intended to provide “new guidance to stop partnerships from using sophisticated tax-free transactions that lack economic substance” to avoid paying taxes. .  The IRS continues to...