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Most taxpayers assume that once they submit a tax return for the year, they will have satisfied the tax reporting rules, and their duty to the IRS is done. For those with more complicated tax situations, they may rely on a tax preparer to make sure e… Read More

If you are facing criminal FBAR charges for failing to disclose your foreign financial accounts, you and your tax attorney may need to get creative in crafting your defense. But as one recent criminal tax case from Massachusetts shows, creativity doe… Read More

Accounts and organizations created under foreign laws do not always fit easily into the Internal Revenue Code’s models, but that does not excuse the founders from following IRS trust reporting requirements. Understanding what counts as a foreign tr… Read More

When the IRS imposes penalties, it can sometimes seem as though the number is plucked from the air. But when an FBAR penalty case goes to trial, the IRS is required to prove the amount of its penalty complied with the law. However, a now-familiar cas… Read More

It’s one thing to owe back taxes and penalties because of your own mistakes. But when your spouse filed on your behalf, sometimes their errors or omissions can come as a shock. When your current or former spouse’s conduct leaves you on the hook f… Read More

Sometimes, the interest earned through foreign mutual funds and investment accounts can result in income taxpayers don’t realize they have. These earnings are often reinvested automatically. If you and your accountant are not careful, an error in d… Read More

How large a penalty is too large, constitutionally speaking? Many people are shocked to learn that the maximum amount for a willful FBAR penalty is one half the balance of the account at the end of the reporting year. This can easily add up to millio… Read More

One day can make all the difference in tax lawsuits. But in Boechler PC v Commissioner of Internal Revenue, the Supreme Court of the United States said that filing a request for a collection due process appeal one day late may not have been enough to… Read More