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September 1, 2022
In Flint v. United States, 2022 WL 3593826 (Fed. Cl. 2022), the court held that the executors of an estate could not recover a six-figure "Title 26 miscellaneous offshore penalty" (MOP)...
December 21, 2021
When a taxpayer utilizes a Tax Preparer, and that Tax Preparer is later investigated by the Internal Revenue Service for fraud and/or other potential…
December 13, 2021
With the increased US Government enforcement of evasion of overseas income, assets, investments, and accounts — offshore tax evasion is a key…