Richard J Sapinski

November 22, 2023 | New Jersey Law Journal

Everyone has probably heard or seen multiple radio or TV ads in the last six months touting the "free money" the federal government is allegedly giving out to businesses under the Employee Retention Credit (ERC) program that Congress enacted in response to the COVID-19 pandemic.

By Richard J. Sapinski and Robert A. Stern

7 minute read

March 24, 2023 | New Jersey Law Journal

In a 5-4 decision in Bittner v. United States, the Supreme Court held that the $10,000 per violation non-willful FBAR penalty, contained in 31 USC § 5321, applies only to each FBAR and not to each account listed in that FBAR.

By Richard J. Sapinski and Joseph B. Shumofsky

8 minute read

April 08, 2020 | New York Law Journal

The IRS is fully aware of the tax avoidance potential of virtual currency and has now deployed its increasing artificial intelligence capabilities to analyze the information obtained from the Coinbase summons and other information it has gathered about the cryptocurrency reporting of U.S. taxpayers.

By Richard J. Sapinski

7 minute read

January 10, 2019 | New Jersey Law Journal

The IRS announced new -- less “taxpayer friendly” -- internal procedures for taxpayers who wish to avoid criminal prosecution for domestic or offshore tax evasion conduct.

By Richard J. Sapinski and Lawrence S. Horn

10 minute read

July 24, 2014 | New Jersey Law Journal

In June, the IRS announced major changes to the terms of its Offshore Voluntary Disclosure Program—should your client consider making use of the revised program?

By Lawrence S. Horn and Richard J. Sapinski

13 minute read

March 02, 2011 | New Jersey Law Journal

IRS voluntary disclosure program gives taxpayers a second chance in 2011

By Lawrence S. Horn and Richard J. Sapinski

9 minute read

July 27, 2010 | New Jersey Law Journal

The IRS recently announced new proposed regulations which clarify (and tighten) the definitions in the existing FBAR rules to make it even more difficult for those U.S. taxpayers who still have not come forward to use artificial structures created for them by advisors both here and abroad to avoid disclosure of their offshore holdings.

By Lawrence S. Horn and Richard J. Sapinski

8 minute read