Facing scrutiny from the Internal Revenue Service’s Criminal Investigation Division (IRS CI) is a serious matter. As its name suggests, IRS CI investigates cases of suspected criminal tax law violations, and these investigations can lead to charges for tax evasion, tax fraud and a host of other federal white-collar crimes.

Most U.S. taxpayers who have offshore bank accounts are required to file an annual Report of Foreign Bank and Financial Accounts (FBAR) with their federal income tax returns. Some are also required to File IRS Form 8938 (which is used to disclose “specified foreign financial assets”). If you were supposed to file an FBAR and/or IRS Form 8938 with your 2022 income tax return but didn’t, what should you do now? Virginia international tax attorney Kevin E. Thorn, Managing Partner of Thorn Law Group, explains:

Prosecuting individuals and companies suspected of fraudulently obtaining PPP and EIDLP loans, tax credits, and other forms of COVID-19 relief remain a top priority for the Internal Revenue Service’s Criminal Investigation Division (IRS CI). IRS CI regularly publishes press releases highlighting its enforcement efforts, and it has made clear that prosecuting pandemic-related fraud will continue as an area of emphasis for the foreseeable future.

In many respects, estate planning and tax planning go hand-in-hand. Failure to consider the tax implications of a proposed planning structure can leave clients and their beneficiaries facing unnecessary tax liability, and this, in turn, can leave estate planners facing allegations of negligence or professional malpractice.

On March 17, 2022, the Internal Revenue Service (IRS) published a Tax Tip reminding taxpayers that they can face penalties for both failure to file and failure to pay. So, what if you aren’t ready to file (or pay) on April 18? Virginia tax lawyer Kevin E. Thorn, Managing Partner of Thorn Law Group, explains.