FBAR
Courts Split on FBAR non-willful Penalty
Should FBAR non-willful penalty be charged per form or per account? The Courts have recently…
Quiet Disclosure Guilty Plea
Florida man pleads guilty to tax evasion and hiding funds around the world In April…
Offshore Disclosure of Foreign Financial Accounts: Deciding What Road to Take
Disclosing Offshore Bank Accounts Taxpayers who are considering coming out of the shadows to disclose…
DOJ Announces Indictment of Taxpayer for Filing False Non-Willful Certification Under the Federal Streamlined Procedures
Case Background On August 27, 2019 the Department of Justice (DOJ) announced a superseding indictment…
Willful FBAR penalty Case Study.
Wilfull FBAR Penalty. The following is intended as an update to my January 26, 2019…
Streamline Disclosures- The Art of the Non-Willful Certification.
Offshore disclosure to IRS. The key to making an offshore disclosure to the IRS using…
The Willful FBAR Penalty: Is it Limited to $100,000? Not so Fast.
Assessment of FBAR penalty Some practitioners have applauded the decision in United States v. Colliot,…
Willful FBAR Penalty- Legal Decisions Diminish Taxpayer Prospects for Successful Defense.
Case Facts. April 3, 2018, the U.S. District Court in United States v. Garrity held…
The Non-willful FBAR Penalty and the Slow Death of Reasonable Cause.
Non Willful FBAR Penalty Ruling. A December 2017 decision of the Court of Federal Claims…
OVDP Coming to an End Soon
Internal Revenue Service plans to close the Offshore Voluntary Disclosure Program (OVDP) on September 18, 2018.…
New Jersey Couple Avoids FBAR Penalty and Instead Receives Warning Letter
The following is an actual FBAR case handled by the Law Office of Anthony N.…
New Developments in The Willful Civil FBAR Penalty
Current Developments May Make It Easier For the IRS To Assess Penalties After Willfully Failing…