Offshore Account UpdatePosted on September 30, 2026
The IRS has announced a new automatic penalty relief program for eligible returns with due dates in 2024 or later. For returns due in 2023 or earlier, the IRS’ existing penalty relief structure will continue to apply. Certain aspects of the IRS’ existing penalty relief structure will continue to apply going forward.
Read MoreOffshore Account UpdatePosted on September 16, 2026
Taxpayers who have failed to report their foreign bank accounts to the federal government can come into compliance by filing a voluntary disclosure. But strict filing requirements (including deadlines) apply, and once it is too late to file, taxpayers must be very careful not to share information the IRS could use to pursue civil or criminal enforcement.
Read MoreOffshore Account UpdatePosted on August 31, 2026
DOJ and IRS FBAR investigations are on the rise. We have seen an increase in these investigations in 2026, with individual and corporate taxpayers facing substantial penalties in many cases. In addition to fines of up to six times the value of a taxpayer’s undisclosed accounts, the DOJ can pursue criminal penalties when warranted.
Read MoreOffshore Account UpdatePosted on August 17, 2026
The IRS recently announced that its long-standing First-Time Abatement (FTA) program is being replaced by a new Automatic Exemption from Penalty (AEP) program, effective in Summer 2026. While taxpayers who are eligible for the AEP will receive penalty relief automatically, others must still take affirmative steps to mitigate their liability exposure.
Read MoreOffshore Account UpdatePosted on July 31, 2026
Facing scrutiny from IRS Criminal Investigation (IRS CI) is a serious matter. IRS CI investigations can lead to charges for both tax-related and non-tax-related offenses, and the U.S. Department of Justice (DOJ) pursues cases based on evidence uncovered during these investigations when warranted. Boston criminal tax lawyer Kevin E. Thorn, Managing Partner of Thorn Law Group, has extensive experience representing clients in these high-stakes matters.
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