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Tax Law’s Two Definitio…

Tax Law’s Two Definitions of Willfulness, and Why They are Different

The definitions of words in the U.S. tax code can be the difference between criminal convictions and financial consequences. Most taxpayers would assume that one word in that code would have one meaning. But when it comes to the definitions of willfu… Read More
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Categories: Tax / IRS Penalties
man in a grey suit standing and holding his painful head with clenching teeth.

FBAR Willfulness Decision is Up to the Jury, Court Says

The difference between a willful and non-willful FBAR penalty against a U.S. taxpayer can be thousands, and sometimes millions of dollars. But how can the IRS know what was going on in your head, and whether your failure to file was on purpose? A rec… Read More
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Categories: FBAR
Domino effect in business.

IRS Eclipses Record FBAR Penalties in New Tax Fraud Lawsuit

A recent federal court tax fraud lawsuit against a woman and her deceased husband’s estate has set a new record for FBAR penalties exceeding over $119.6 million. Find out what the IRS says she and her husband did to deserve such a steep penalty. Hu… Read More
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Gold Bitcoins

Do You Need to Report Cryptocurrency on Your FBAR?

Where does an entirely virtual financial institution exist: on your phone, in a server-farm somewhere? Could the location of the founding company turn your Bitcoin wallet into a foreign financial institution? If so, you may need to report cryptocurre… Read More
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Categories: FBAR
Many coins of various cryptocurrencies

IRS Promises Guidance on Reporting Cryptocurrency on Your Tax Returns

Preparing your own tax returns is hard enough when you are a regular employee with standard deductions. But what about when some of your currency only exists digitally? What do you need to know about reporting cryptocurrency on your tax returns? Will… Read More
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Categories: Tax / IRS Penalties
IRS Tax form 1040

IRS Voluntary Disclosure Can Promise Tax Fraud and Heavy FBAR Penalties

When taxpayers with foreign financial accounts take advantage of the IRS voluntary disclosure practice, they know that mistakes have been made, and that penalties will follow.  But they probably don’t think of themselves as “tax criminals”. Th… Read More
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Categories: Tax / IRS Penalties
Frayed cables breaking apart at the last strand.

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

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