Failing to disclose an individual or corporate taxpayer’s foreign bank accounts to the federal government can have serious consequences. Not only can noncompliance lead to substantial fines, but it can also lead to federal prison time in some cases. With DOJ and IRS FBAR investigations on the rise, taxpayers need to prioritize compliance in 2026.

The IRS has established a new Automatic Exemption from Penalty (AEP) program that will streamline relief for eligible taxpayers. For those who are not eligible, nothing is changing. In all cases, delinquent taxpayers need to make informed decisions about coming into compliance, as IRS audits and investigations can lead to serious consequences.

Criminal tax fraud investigations can lead to various charges under federal law. When targeted in these investigations, taxpayers must execute informed, comprehensive, and cohesive defense strategies that take into account all of the allegations (and potential allegations) involved. This starts with engaging an experienced New Jersey criminal tax lawyer promptly.

The Internal Revenue Service (IRS) recently labeled most Charitable Remainder Annuity Trusts (CRATs) as “listed transactions.” While this does not mean that CRATs are inherently unlawful, it does mean that the IRS is paying particular attention to U.S. taxpayers who use CRATs for tax mitigation purposes.

The Internal Revenue Service (IRS) is sending settlement letters to eligible taxpayers with pending conservation easement disputes. Taxpayers who receive these letters must accept the IRS’s offer within 90 days to avoid additional liability, though taxpayers must also make informed decisions about whether to settle with the IRS at all. Taxpayers who have claimed valid conservation easement deductions should not accept liability unnecessarily.