FBAR
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?
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…
Quiet Disclosures and the Civil Willful FBAR Penalty. Even Death Will Not Help You
The Government will examine efforts by a Taxpayer to avoid detection by the Internal Revenue…
Former Harvard Chemistry Chair indicted for failing to file FBAR and filing false tax returns
IRS Hard at Work Despite the Pandemic Individuals, who have failed to report their foreign…
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…