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What happens when the IRS refers your case to Criminal Investigation. A 32-year tax attorney explains when you need a criminal tax lawyer.
Foreign crypto reporting spans Form 1040, FBAR, Form 8938, Form 8621, Form 5471, and others. Here is the complete form stack and how the pieces
Foreign crypto exchange accounts like Binance are FBAR-reportable when the $10,000 threshold is met. Here is the analysis and what to do if you have
Foreign crypto exchanges trigger U.S. income reporting, possible FBAR, and Form 8938 filings. Here is the full framework and how to comply with each piece.
Ignoring Form 5471 stacks penalties at $10,000 per year per corporation, extends the statute of limitations, and can trigger criminal exposure in some cases.
Most U.S. persons with foreign corporate ownership need to file Form 5471 and related forms. Here are the thresholds, the attribution rules, and the common
The $10,000 Form 5471 penalty has multiple paths to relief: reasonable cause, disclosure programs, and procedural challenges. Here is how each one works.