This article examines the concept of willfulness in the context of international tax enforcement, focusing on the factors that can transform a civil tax case into a criminal tax matter.
This article provides advice for guiding clients that seek to discharge taxes in bankruptcy and practical guidance to help avoid common...
On Oct. 14, 2021, the Ninth Circuit Court of Appeals in Berkovich affirmed the decision from the Bankruptcy Appellate Panel (BAP) that...
This article examines strategies for handling an IRS investigation of international returns, and recommends ways to improve audits,...