FBAR
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…
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? Complete US Tax Guide
Saving for retirement should bring peace of mind. But when your pension is from outside…
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, But throws the Taxpayer a Bone
By: Anthony N. Verni Attorney at Law, CPA September 5, 2024 ©2024 Eleventh Circuit…
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
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
On February 28, 2023, in Bittner v United States, 598 U.S. (2023) the U.S. Supreme…
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 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?
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
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…