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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
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
Liechtenstein flag is waving at a beautiful and peaceful sky in day time while sun is shining.

The Muddier Waters of Willful FBAR Penalty Maximums

From the Court of Federal Claims to District Courts across the country, it seems everyone has an opinion on whether an old IRS regulation caps willful FBAR penalty maximums well below the amounts authorized in the statute. Now a new decision further… Read More
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Categories: FBAR
A letter from the IRS.

What to Do if You Receive a Soft Letter from the IRS

Enforcement at the IRS is getting tighter. Now that the Offshore Voluntary Disclosure Program is closed, taxpayers with foreign financial accounts are facing the possibility of higher penalties and tighter scrutiny of their offshore assets. One metho… Read More
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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
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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