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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

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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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… Read More
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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… Read More
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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… Read More
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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… Read More
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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… Read More
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