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Would You Rather Pay Many Smaller FBAR Penalties, or One Big One?

When tax attorneys came together at the New York University Tax Controversy Forum, everyone was talking about recent cases over the upper limit of willful FBAR penalties on a single account. But for one speaker, the question was which was worse: bein… Read More
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Categories: FBAR
The Ambassador Bridge linkink Detroit, Michigan, USA with Windsor, Ontario, Canada. The national flags of the USA and of Canada are notable in the foreground.

Court Tells U.S. Taxpayer Living Abroad, Pay First, Sue Second

If you are a foreign resident but a U.S. taxpayer, it can be especially difficult to find the right way to challenge an unfair tax assessment. You may question if internal IRS appeals are enough, or whether you have the right to refuse payment and su… Read More
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Categories: Tax / IRS Penalties
huge deposit of one hundred dollar stacks

California Case Signals Bigger Non-Willful FBAR Penalties to Come

When you open a new financial account overseas, it often is technically more than one account. You may have both checking and savings accounts at a foreign bank. Or your investments may be divided into different accounts with different investment str… Read More
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Categories: FBAR
Payment notification. Serious unhappy elderly woman sitting together with her husband and looking at the document while holding it

IRS Seizes Social Security Benefits to Pay Tax Debt: Should You Be Worried?

When Motown writer Edward J. Holland, Jr., owed the IRS nearly $20 million, the agency took some extreme steps to collect on the tax debt. It even seized 100% of his social security payments. Find out how the IRS could do that, and whether you need t… Read More
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Categories: IRS Debt Collection
New York, NY, USA - Motown: Broadway musical

IRS Places Levy on Royalties to Motown Artist for Unpaid Tax Debt

Being a Motown artist behind famous songs like “Stop in the Name of Love” and “You Keep Me Hangin’ On” doesn’t excuse not paying millions of dollars in tax debt. But did the IRS go too far when it placed a levy on royalties owed to Gold F… Read More
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Categories: IRS Debt Collection
Liechtenstein flag is waving at a beautiful and peaceful sky in day time while sun is shining.

The Muddier Waters of Willful FBAR Penalty Maximums

From the Court of Federal Claims to District Courts across the country, it seems everyone has an opinion on whether an old IRS regulation caps willful FBAR penalty maximums well below the amounts authorized in the statute. Now a new decision further… Read More
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Categories: FBAR
Person having American passport for inspection

Will They Stop You At the Airport for Your Tax Debt?

There has been a lot of news lately about the IRS certifying taxpayers to the State Department for seriously delinquent tax debt. Certification means a taxpayer’s passport will not be renewed and could be revoked. If you are behind on your taxes, d… Read More
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Categories: IRS Debt Collection
A letter from the IRS.

What to Do if You Receive a Soft Letter from the IRS

Enforcement at the IRS is getting tighter. Now that the Offshore Voluntary Disclosure Program is closed, taxpayers with foreign financial accounts are facing the possibility of higher penalties and tighter scrutiny of their offshore assets. One metho… Read More
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Hand holding U.S. passport

U.S. Tax Court Can Now Hear Tax Passport Certification Cases

Receiving a notice from the IRS is always stressful. When that document tells you that your passport could be affected, it can make you nervous to exercise your constitutional right to international travel. New changes to the U.S. Tax Court’s rules… Read More
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Categories: Tax / IRS Penalties
Marble columns and stairs

How to Challenge a Penalty for Willful FBAR Violations

If you have been assessed a civil penalty for willful FBAR violations, you may be wondering whether the IRS has the final say. Find out how to challenge a penalty for willful FBAR violations, and how the courts will decide whether or not you have to… Read More
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Categories: FBAR

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