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One Form, One Non-Willful FBAR Penalty, Circuit Court Says

How many penalties can the IRS assess for a single missed form? That was the question before the Ninth Circuit Court recently in United States v Boyd. At least where an accurate FBAR report was filed late, the Court ruled that the one form and one vi… Read More
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Can the IRS Impose FBAR Penalties if You Don’t Owe Taxes?

Many retired U.S. taxpayers don’t owe taxes at the end of the year. If their income from pre-tax retirement accounts and Social Security is offset by medical expenses or other allowable deductions, they may not have enough income to report, or any… Read More
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legal documents

IRS Says Due Process Only Requires Written Response, Not a Hearing

What opportunity should you have to dispute an IRS penalty before it is assessed? Should you be able to take the government to court? What about an administrative hearing by the IRS Appeals Office? In a recent motion to dismiss a taxpayer’s complai… Read More
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Foreign Money

Court Finds Drug CEO’s FBAR Violations Willful, Even if Unintentional

Can the IRS assess penalties for willful FBAR violations if the taxpayer didn’t mean to lie to the government or hide assets? In a second opinion, one federal judge in Pennsylvania has ruled that a drug company’s CEO owed more than $1 million in… Read More
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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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