Severity Under Scrutiny: The U.S. Supreme Court Battle Over the FBAR Penalty

Abstract In recent years, Congress strengthened federal regulation of foreign bank accounts held by United States citizens. In 1970, Congress passed the Bank Secrecy Act (BSA), req ...

Proposed Regs Could Cast a Wider Net for Microcaptive Scrutiny

by Chandra Wallace The microcaptive reportable transaction regulations proposed April 10 mean a whole new set of transactions are now listed transactions — considered abusive by ...

Civil War II : The Constitutionality of California’s Travel Bans

Abstract California, along with a few other states leaning toward the liberal side of America’s political system, enacted a series of laws banning state-funded or state-sponsored ...

The Ruling on Reserve Mechanical Corp. v. Commissioner, and Impact to Captive Insurance Tax Benefits

Beckett Cantley  Geoffrey Dietrich This article provides an overview of the May 13 th , 2022, U.S. Tenth Circuit Court of Appeals decision in Reserve Mechanical Corp. v. Commissio ...

Biden Signs $1.5 Trillion Spending Bill Without Tax Offsets

Are The “Build Back Better” Taxes Lurking? By Beckett Cantley 1 & Geoffrey Dietrich 2 On March 10, 2022, the U.S. Senate voted 68-31 to pass the Fiscal Year (FY) 20 ...