Robert F. Smith

Background and Non-Prosecution Agreement


Mr. Smith in 2020, at the age of 57, entered into a Non-Prosecution Agreement, NPA, with the IRS.   Let’s look at what I believe happened to Mr. Smith to cause his personal and professional life to intersect with potential Criminal Prosecution with the United States Government.  Let’s also see what could have been done differently to head off such a horrible outcome to his reputation, his freedom, and a lifelong stain on his legacy.

Finally, let’s see if this is now the end of Mr. Smith’s criminal and civil problems with the successful negotiation of this NPA.



Legal Requirements for Hemp-Related Business Customers.


The Financial Crimes Enforcement Network (FinCEN) periodically provides guidance for hemp-related business customers (HRBC).  We will also talk about FinCEN conduct towards HRBC as well as how FinCEN collects and gathers information in relation to both the Bank Secrecy Act and Anti-Money Laundering (BSA/AML) regulatory requirements. 

First, we need to define a few institutions and definitions that will assist the reader to understand this article as it may apply to them or their clients, but is not intended to be legal advice and is time-sensitive with rapidly expanding regulations from FinCEN, BAS, and AML.  Also, we explain how financial institution

10.82 Expedited suspension (a) When applicable. Whenever the Commissioner, or delegate, determines that a practitioner is described in paragraph (b) of this section, the expedited procedures described in this section may be used to suspend the practitioner from practice before the Internal Rev

For this year, 2020, there are some key items to consider involving credits, deductions, and refunds:

Recovery Rebate Credit/Economic Impact Payment.

Taxpayers who received an Economic Impact Payment should keep their Notice 1444, Your Economic Impact Payment, with their 2020 tax records. You may be eligible to claim the Recovery Rebate Credit  on your tax year 2020 federal income tax return if:

you didn’t receive an Economic Impact Payment, or your Economic Impact Payment was less than $1,200 ($2,400 if married filing jointly for 2019 or 2018), plus $500 for each qualifying child you had in 2020.

If you didn’t receive the full amount of the Economic Impact Payment for which you were eligible, you may be able to claim the Recovery Rebate Credit when you file

How much did Colin Kaepernick actually receive from his “opting out” of the contract with the San Francisco Giants following the 2016 season and the recent  Collective Bargaining Agreement, (CBA), with the NFL.[1]  In a recent interview between Kaepernick’s attorney, Mark Geragos and

So, this year you are preparing your own tax return, no need for a CPAs, Enrolled Agent or Tax Attorney…great!

But have you thought about “FBAR” and your 2018 tax return!!!

You might ask, do I have to worry about this FBAR quagmire if I have never been outside of the United States?


What triggers this FBAR compliance for me?

Usually this is triggered when you have foreign interest on your form 1099-int.  You investments from your money managers, such as Schwab, Merrill, Wells Fargo, etc.… will send you this rather thick packet of how your investments have performed for 2018 that have a summary page at the front.   Now look to see if you have “foreign interest” and/or “foreign tax paid”.  If

FOREIGN TRUST WITH U.S. JURISDICTION? FRACTIONAL OWNERSHIP OF A FOREIGN ENTITY? BEWARE!!! The Tax Season for filing 2018 tax returns is now upon us and the full brunt of the Tax cuts and Job Act (TCJA) will occupy tax compliance by both the Taxpayers and the Tax Preparers.  One of the most stag