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Fourth Circuit Adopts “Recklessness” Standard For Willful FBAR Violation and Rejects $100,000 Willfulness Penalty Cap Argument.

If you decide to take advantage of more favorable terms and interest rates in foreign financial accounts, you may not realize how significantly those investment choices may complicate your tax filing requirements. Failing to file annual FBAR reports… Read More
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foreign currency

When Do You Have a Financial Interest in Foreign Bank Accounts for FBAR Filings?

If you have a complicated banking situation, including business entities and shared accounts with non-U.S. taxpayers, it may not be clear when you have a financial interest in foreign bank accounts that requires disclosure under the IRS regulations r… Read More
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Fifth Amendment papers

Can You Plead the Fifth Amendment on FBAR Filings?

After spending years trying to hide money in a “secret account” in Switzerland, one couple was assessed civil willful FBAR penalties after they filed a report that simply said “Fifth Amendment”. The tactic raises the question, can you plead t… Read More
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Different forms of currency

What Are the FBAR Reporting Requirements for U.S. Citizens Living Overseas?

If you are an American citizen whose work, family, or lifestyle have sent you to live overseas, you may wonder whether you are still required to file U.S. tax returns or disclose your foreign assets. A recent complaint filed by the IRS in the United… Read More
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Categories: FBAR
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International Spouse Challenges $5 Million FBAR Penalty

When international spouses live, work, and pay taxes in multiple countries, it can create difficulties knowing who needs to disclose what accounts to the IRS. One U.S. taxpayer recently filed suit against the IRS over a willful FBAR penalty of more t… Read More
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foreign money

Do You Have to Report Your Business’s Foreign Financial Accounts on Your FBAR?

If you are operating a business with accounts overseas, it may make sense to maintain foreign financial accounts in those countries to make doing business easier. But as a business owner, choosing to open bank accounts in other countries may create t… Read More
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disabled man in a wheelchair stopped in front of a staircase

Is a Disability Discrimination Award Taxable as Income?

By the time a wrongfully terminated employee receives their disability discrimination award after filing an employment discrimination lawsuit, much of that money is already earmarked for lawyers, medical providers, and other bills that have come due.… Read More
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Gavel and Themis statue in the court library.

Non-Willful FBAR Penalties Capped Per Year, Not Account, Court Says

Could the way you do your banking affect how much you pay in IRS filing penalties? Until recently, the answer was universally yes. Now a federal district court judge in Texas has said that for non-willful FBAR penalties, Congress set the cap per year… Read More
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Gavel, calculator and money

IRS Sues Adult Children to Collect Their Parent's Tax Debt and FBAR Penalties

Tax debt is notoriously hard to get rid of. The IRS is a zealous creditor with some tax liabilities even surviving bankruptcy. If you owe significant unpaid taxes, the IRS has a variety of ways to collect on that debt. But could those collections aff… Read More
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Categories: IRS Debt Collection
Scales of Justice weighing cash

Married Spouses’ Willful FBAR Penalties Are Double, Treasury Department Says

Most married couples manage their money together. They may hold accounts jointly, or each keep their names on their own assets. But according to a recent complaint filed by the United States Secretary of Treasury, even keeping accounts in one spouse… Read More
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