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FBAR IRS collection

Can the IRS Collect Non-Willful FBAR Penalties from a Deceased Taxpayer’s Estate?

There’s an old saying that nothing is inevitable but death and taxes. But in a fight between the two, which one wins? If a person dies before paying off an assessment, can the IRS collect non-willful FBAR penalties from the deceased taxpayer’s es… Read More
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Categories: FBAR, Tax News
Appeals Judges Disagree O…

Appeals Judges Disagree Over Maximum Willful FBAR Penalty

The question of just how expensive a willful penalty for failing to report foreign financial accounts has been making its way through the federal court systems. Now, the Second Circuit has issued a split opinion that shows just how divided judges are… Read More
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CPA

CPA Should Have Known About FBARs, Asked Questions, Court Says

Many taxpayers facing audits over their foreign financial accounts say they relied on their CPA or accountant and didn’t know they had a duty to file FBAR reports. But when the taxpayer was a CPA himself, his claims of ignorance weren’t enough to… Read More
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Categories: FBAR, Tax News
Lawsuit

Plaintiff Tries to Dismiss His Own FBAR Lawsuit and Fails

Why would you file a lawsuit against the IRS just to turn around and ask the District Court to dismiss it? A combination of impatience, new precedent, and personality changes left a Plaintiff looking for a way out of the Federal Court of Claims. Inte… Read More
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Emergency fund

Inherited Secret Emergency Account Caused Willful FBAR Violations, Appeals Court Says

Is there ever a good reason to hide something from the IRS? A recent opinion from the U.S. Federal Circuit Court of Appeals suggests that even the best of reasons won’t matter if a taxpayer is later found to have willfully failed to file FBAR forms… Read More
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searching for files in a filing cabinet

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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woman reviewing tax documents

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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Scissors cutting into money bag

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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