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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…
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…
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…
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…
Woman reviewing willful FBAR penalties

Is the IRS Breaking its Own Rules for Willful FBAR Penalties?

The Secretary of Treasury and the Internal Revenue Service (IRS) are controlled by a number of laws and regulations that set the rules for issuing taxes, fines, and penalties against U.S. taxpayers. But when the law related to willful FBAR penalties…
Redacted IRS Case History

Can an IRS Case History Prove Non-Willfulness?

When you are facing willful FBAR penalties, you need all the help you can get to prove that your failure to file reports of foreign financial accounts was not intentional or reckless. But could the IRS’s own records help you win your case? Can…
U.S. Constitution

IRS Says FBAR Penalty Is Not a Fine Under Eighth Amendment

Willful FBAR penalties can quickly add up to hundreds of thousands of dollars. But are those penalties an unconstitutional fine under the Eighth Amendment? In a recent filing in the United States Court of Federal Claims, the government said the amoun…
IRS Agent Showing Red Card for Willful Violation of FBAR Reporting Requirements

What Do Willful Violations of FBAR Reporting Requirements Look Like?

The difference between penalties for willful violations of FBAR reporting requirements and non-willful violations could be hundreds of thousands of dollars, federal criminal charges, and prison time. But it can be hard for taxpayers to know what to e…
Using Smartphone as Calculator - Determining PFIC Excess Distribution Interest Penalties

PFIC 101: How to Avoid PFIC Excess Distribution Interest Penalties

Once U.S. taxpayers identify passive foreign investment company assets in their portfolio, the next logical step is to minimize the tax consequences connected to those assets. At the top of the list is finding a way to avoid PFIC excess distribution…
Photo of Woman Pointing with Pen to PFIC stock interests Line Item on Printout

PFIC 101: How to Tell if You Have PFIC Stock Interests

It may seem easy to know whether a U.S. taxpayer has stock interests overseas. You may think that you will cross that bridge if and when you decide to invest in a foreign investment company. But you may have PFIC stock interests you don’t recog…

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