FBAR

FBAR

Russian Pension

Russian Pensions, FBAR Reporting, and the Suspension of the U.S.–Russia Tax Treaty 

Introduction  The U.S. government’s suspension of the U.S.–Russia Income Tax Convention, effective 2024, has created…

How to File Late FBARs Using Delinquent FBAR Submission Procedures

Delinquent FBAR Submission Procedures

Missing the Report of Foreign Bank and Financial Accounts (FBAR) deadline happens more often than…

Are foreign pensions taxable in the US?

Are Foreign Pensions Taxable in the US? Complete US Tax Guide

Saving for retirement should bring peace of mind. But when your pension is from outside…

Criminal FBAR enforcement

Recent Developments in Criminal FBAR Enforcement in 2023–2025

From 2023 through mid-2025, FBAR (FinCEN Form 114) compliance evolved into a criminal law flashpoint.…

Eleventh Circuit Sustains Willful FBAR Penalty.

Eleventh Circuit Sustains Willful FBAR Penalty, But throws the Taxpayer a Bone

By: Anthony N. Verni Attorney at Law, CPA September 5, 2024 ©2024   Eleventh Circuit…

Taxpayers Personal crisis

TAXPAYER’S PERSONAL CRISIS NO DEFENSE TO WILLFUL FBAR PENALTY

By: Anthony N. Verni, Attorney at Law, CPA August 13, 2024 ©2024   TAXPAYER’S ADHD…

FBAR PROSECUTIONS-FORMER CFO SENTENCED TO EIGHTY SIX MONTHS IN PRISON

FBAR PROSECUTIONS-FORMER CFO SENTENCED TO EIGHTY SIX MONTHS IN PRISON

On September 21, 2023 a  former CFO of  a Russian natural gas company was sentenced…

FBAR PENALTY RELIEF FOR TAXPAYERS. NON-WILLFUL FBAR PENALTY IS TO BE ASSESSED PER FORM

FBAR PENALTY RELIEF FOR TAXPAYERS. NON-WILLFUL FBAR PENALTY IS TO BE ASSESSED PER FORM

On February 28, 2023, in Bittner v United States, 598 U.S. (2023) the U.S. Supreme…

FATCA REPORTING CHANGES

FATCA REPORTING CHANGES AND INFLATION REDUCTION ACT SPELL TROUBLE FOR TAXPAYERS WHO HAVE FAILED TO FILE FORM 8938 AND FBARS

A recent report (the “Report”) from The Treasury Inspector General for Tax Administration (“TIGTA”) addressing…

FIFTH CIRCUIT RULES

FIFTH CIRCUIT RULES NON-WILLFUL FBAR PENALTY IS PER ACCOUNT AND NOT PER FORM

The Fifth Circuit recently held in United States v. Bittner,  ___ F. 4th ___ (5th…

CAN THE FBAR PENALTY MITIGATION GUIDELINES LOWER YOUR FBAR PENALTY OBLIGATION?

NAVIGATING THE FBAR PENALTY MITIGATION GUIDELINES Failure to report your foreign financial accounts on Report…

COURT ORDERS REPATRIATION OF FOREIGN ASSETS TO AID IN FBAR PENALTY COLLECTIONS

The issue of whether the Government can repatriate a taxpayer’s foreign assets for purposes of…