FBAR
FBAR Penalties After Assessment: Litigation & Defense Options
An FBAR penalty changes things the moment it is assessed. What had been under review…
FBAR Penalty Notice: Your 30-Day Legal Action Plan to Appeal or Negotiate with the IRS
An Internal Revenue Service (IRS) Report of Foreign Bank and Financial Accounts (FBAR) penalty notice…
FBAR Filing Instructions: What Documents You Need Before You Start
Filing the Foreign Bank Account Report (FBAR) feels a lot easier when you start with…
Evolving FBAR Enforcement: Are International Efforts Keeping Pace with Modern Offshore Concealment Techniques?
Introduction The Report of Foreign Bank and Financial Accounts (“FBAR”) requirement, mandated under 31 U.S.C.…
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…