Could Tax Treaties Exempt Expatriates from Filing FBARs?
February 8th, 2024
Expatriates often have a foot in two (or more) countries, physically and financially speaking. This can make it difficult to understand their U.S. tax filing requirements. Add to that the extra requirement of filing FBARs disclosing foreign financial…
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Categories: FBAR
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Who Has to Disclose Foreign Financial Accounts on FBARs?
January 9th, 2024
Understanding the reporting requirements for U.S. taxpayers with finances overseas can be confusing. It isn’t as easy as whose name is on the account. A recent Court decision provides a helpful guide to determine who has to disclose foreign financi…
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Categories: FBAR
Can Translation Errors Excuse Willful Failure to File FBAR?
December 11th, 2023
The U.S. tax code, including the reporting requirements for foreign bank accounts, can be confusing at best. Non-English speaking taxpayers face additional hurdles due to risks of translation errors and problems understanding the English language, in…
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Categories: FBAR
IRS Must Repay Innocent Spouse Widow for Tax Lien, Court Says
November 9th, 2023
Everyone makes mistakes, and that includes the IRS. When the IRS collected an overpayment of unpaid taxes from a widow who qualified as an innocent spouse, the United States Tax Court told the government to give the money back. IRS Assesses Tax Lien…
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Categories: Tax / IRS Penalties
Could Your Estate Have to Pay Your FBAR Penalties?
October 9th, 2023
When the IRS issues FBAR penalties against elderly taxpayers, they may have an instinct to ignore the issue and hope it goes away after their death. However, a recent United States District Court case, United States v Gaynor, says your estate could h…
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Categories: FBAR
Tax Deficiency Petition Deadline Isn’t Absolute, Appeals Court Says
September 8th, 2023
It is an unfortunate truth that many U.S. taxpayers wait until the last minute to deal with the IRS. This may mean filing extensions on their tax returns, or delaying contacting a tax attorney to respond to a deficiency notice. But is there ever a go…
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Categories: IRS Debt Collection
IRS Lacks Authority to Assess Penalties for Failure to Report Foreign Business Ownership, Tax Court Says
August 4th, 2023
U.S. taxpayers must disclose their ownership interests in foreign corporations to the IRS in yearly reports. The failure to report foreign business ownership can result in steep penalties. But a recent United States Tax Court case says that the IRS…
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Categories: Tax / IRS Penalties
Willful Blindness Leads to Willful FBAR Penalties After Doctor Hides Assets
July 6th, 2023
Taxpayers can’t turn a blind eye to their IRS filing requirements and expect to avoid willful FBAR penalties. A recent decision from the United States District Court for the Eastern District of Michigan shows that when an anesthesiologist tried to…
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Categories: FBAR
U.S. Supreme Court Excuses Secret IRS Summons, Sometimes
June 7th, 2023
Do you have the right to notice when the IRS demands production of your financial information? If the IRS reaches too far, do you have the right to take the government to court and limit that reach? The recent unanimous United States Supreme Court de…
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Categories: IRS Debt Collection
When Are Rental Real Estate Losses Not Deductible?
May 8th, 2023
Many U.S. taxpayers find themselves as landlords even while working full time in another industry. When the cost of owning a rental property starts to add up, you may wonder whether those costs can help offset your income on your U.S. tax returns. A…
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Categories: Tax Deductions
