Experienced · Local · Affordable

» FBAR

Federal Circuit Court Wei…

Federal Circuit Court Weighs In on Willful FBAR Penalty Cap Issue

The question of just how expensive an IRS willful FBAR penalty can be has been making its way through trial courts across the country for more than a year. Now the first of those cases are coming up on appeal. As the Federal Circuit Court weighs in o… Read More
Read More
Categories: FBAR
man in a grey suit standing and holding his painful head with clenching teeth.

FBAR Willfulness Decision is Up to the Jury, Court Says

The difference between a willful and non-willful FBAR penalty against a U.S. taxpayer can be thousands, and sometimes millions of dollars. But how can the IRS know what was going on in your head, and whether your failure to file was on purpose? A rec… Read More
Read More
Categories: FBAR
Domino effect in business.

IRS Eclipses Record FBAR Penalties in New Tax Fraud Lawsuit

A recent federal court tax fraud lawsuit against a woman and her deceased husband’s estate has set a new record for FBAR penalties exceeding over $119.6 million. Find out what the IRS says she and her husband did to deserve such a steep penalty. Hu… Read More
Read More
Gold Bitcoins

Do You Need to Report Cryptocurrency on Your FBAR?

Where does an entirely virtual financial institution exist: on your phone, in a server-farm somewhere? Could the location of the founding company turn your Bitcoin wallet into a foreign financial institution? If so, you may need to report cryptocurre… Read More
Read More
Categories: FBAR
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
Read More
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
Read More
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
Read More
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
Read More
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
Read More
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
Read More

For More Information

  • This field is for validation purposes and should be left unchanged.

closeClose