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Category: Offshore Account Update

How Do the Risks of IRS Audits and IRS CI Investigations Differ?

Offshore Account Update

Posted in on July 31, 2026

While IRS audits are civil in nature, IRS CI investigations are focused on gathering the evidence needed to substantiate criminal charges. With that said, audits can (and do) lead to criminal charges as well. In all cases, taxpayers that are at risk of facing criminal charges must build and execute a comprehensive defense strategy, and this starts with engaging an experienced Virginia criminal tax attorney.

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Understanding the Tax Risks Associated with Charitable Remainder Annuity Trusts

Offshore Account Update

Posted in on July 17, 2026

The Internal Revenue Service (IRS) has issued new final regulations labeling most Charitable Remainder Annuity Trusts (CRATs) as “listed transactions.” As a result, CRATs are now subject to additional reporting requirements. Additionally, regardless of whether taxpayers comply with their reporting obligations, using a CRAT for tax mitigation purposes could lead to invasive IRS scrutiny.

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IRS Announces “Time-Limited Settlement Opportunity” for Pending Conservation Easement Disputes

Offshore Account Update

Posted in on June 30, 2026

The Internal Revenue Service (IRS) is seeking to reduce its backlog of conservation easement cases by offering a new “time-limited” settlement opportunity to eligible taxpayers. Taxpayers who receive settlement letters under the IRS’ initiative must make an informed decision about whether to accept based on their potential liability exposure. This requires working with a Virginia tax lawyer who is experienced in this complex area of Internal Revenue Code compliance.

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The IRS is Focused on Conservation Easement Fraud Enforcement: What VA Taxpayers Need to Know

Offshore Account Update

Posted in on June 12, 2026

Allegations of conservation easement fraud can expose taxpayers to substantial penalties—including criminal penalties in some cases. The Internal Revenue Service (IRS) has recently begun prioritizing fraud in this area. Taxpayers who are facing investigations need to defend themselves effectively, while those who have received settlement letters under the IRS’ “time-limited” settlement program need to make informed decisions. This starts with hiring an experienced Virginia tax attorney.

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The IRS and DOJ Are Targeting Small Businesses, Construction Companies and Their Executives in 2026

Offshore Account Update

Posted in on May 29, 2026

The Internal Revenue Service (IRS) and U.S. Department of Justice (DOJ) are targeting small businesses, construction companies, and their executives in 2026. We have recently seen an increase in criminal tax fraud investigations targeting these taxpayers, with some leading to federal prosecution. As Virginia criminal tax attorney Kevin E. Thorn, Managing Partner of Thorn Law Group, explains, avoiding prosecution in these cases requires an informed and strategic defense—and, for those who are not yet under investigation, proactively coming into compliance could be critical to avoiding unwanted scrutiny.

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