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Scales of Justice weighing cash

Married Spouses’ Willful FBAR Penalties Are Double, Treasury Department Says

Most married couples manage their money together. They may hold accounts jointly, or each keep their names on their own assets. But according to a recent complaint filed by the United States Secretary of Treasury, even keeping accounts in one spouse… Read More
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Woman signing tax forms

IRS Says Widow Committed Willful FBAR Violations Just by Signing Tax Returns

In many relationships, one spouse may handle all the financial affairs of the household. But what happens when that spouse dies? Can a widow (or widower) be assessed a willful FBAR penalty just for signing tax returns prepared by her spouse and a CPA… Read More
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How Courts Calculate Will…

How Courts Calculate Willful FBAR Penalties

If things have gone wrong and you find yourself and your overseas bank accounts the subject of an IRS audit, you may feel like you are preparing for the worst. But what is the worst? How do the IRS and tax courts calculate willful FBAR penalties when… Read More
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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
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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
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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
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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
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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
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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

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