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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
Businessman in handcuffs

U.S. Prosecutors Claim First FATCA Criminal Conviction

The Foreign Account Tax Compliance Act (FATCA) was designed to help the U.S. government track down undisclosed taxable assets overseas. Many say enforcement has been ineffective so far. Now U.S. prosecutors are claiming their first FATCA criminal con… Read More
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Categories: FATCA
Woman and Man Facing Each Other Across Gap in Broken Bridge

Court Decision Widens Divide on Maximum Willful FBAR Penalties

What does it mean to willfully fail to file foreign financial account reports or make false statements on your tax returns? Can you willfully violate a rule you didn’t know existed? And if you do, how much should you be charged? These aren’t new… Read More
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The US Treasury Department Building

Treasury Dept. Announces New Voluntary Disclosure Practice

Now that the OVDP is no longer available, what will taxpayers with undisclosed foreign assets do? The U.S. Department of Treasury has announced a new voluntary disclosure practice as an option for those trying to avoid possible criminal consequences.… Read More
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Categories: FBAR, OVDP
Digital Files - FBAR Database

Government Watchdog Says FBAR Database Lacks Quality Controls

When the IRS singles you out for an audit or FBAR investigation, you assume that the process will have certain controls to be sure things are done properly. But a recent report by the Government Accountability Office, a government watchdog agency, re… Read More
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Categories: FBAR
Whistleblower

Changes to Whistleblower Law Could Mean More FBAR Investigations

Whistleblowers have long been a strategic part of how the IRS investigates potential tax fraud cases. Now a change to whistleblower law will mean those who disclose unreported international accounts could receive rewards based on FBAR penalties and c… Read More
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U.S. Supreme Court May Rule on FBAR

Resolving the FBAR Penalty Conflict: Will Taxpayers Have to Pay More?

The federal district courts and the court of claims have come down on opposite sides and created an FBAR penalty conflict. Could the issue be headed for the Supreme Court? Or will U.S. taxpayers with financial accounts overseas end up paying more reg… Read More
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Disintegrating Dollar Sign - Symbol of higher maximum willful FBAR penalties

Federal Court Says 2004 Law Raised Maximum Willful FBAR Penalties​

Three federal district courts have said the IRS is breaking its own rules by imposing penalties beyond a Treasury Department regulation. But the federal Court of Claims says a 2004 law raised the maximum willful FBAR penalties. That decision could co… Read More
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Dollar Folded into Arrow Pointing Down - Lower FBAR Penalties

The Case(s) for Lower Willful FBAR Penalties

Not disclosing your foreign bank accounts to the IRS can quickly become a costly mistake. But has the IRS been imposing penalties for failure to file FBAR forms that are even higher than it should? There is a case to be made for lower willful FBAR pe… Read More
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