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Update: Sixth Circuit Court Calls FBAR Filing Failures “Objectively Reckless”

The Sixth Circuit Court of Appeals, which controls much of the Midwest, has joined several other appellate courts to confirm that recklessness is enough to support willful penalties for FBAR filing failures. Reviewing the case of United States v. Kel… Read More
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Could Tax Treaties Exempt Expatriates from Filing FBARs?

Expatriates often have a foot in two (or more) countries, physically and financially speaking. This can make it difficult to understand their U.S. tax filing requirements. Add to that the extra requirement of filing FBARs disclosing foreign financial… Read More
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Who Has to Disclose Foreign Financial Accounts on FBARs?

Understanding the reporting requirements for U.S. taxpayers with finances overseas can be confusing. It isn’t as easy as whose name is on the account. A recent Court decision provides a helpful guide to determine who has to disclose foreign financi… Read More
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Can Translation Errors Excuse Willful Failure to File FBAR?

The U.S. tax code, including the reporting requirements for foreign bank accounts, can be confusing at best. Non-English speaking taxpayers face additional hurdles due to risks of translation errors and problems understanding the English language, in… Read More
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Money and Justice

Could Your Estate Have to Pay Your FBAR Penalties?

When the IRS issues FBAR penalties against elderly taxpayers, they may have an instinct to ignore the issue and hope it goes away after their death. However, a recent United States District Court case, United States v Gaynor, says your estate could h… Read More
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Willful Blindness Leads to Willful FBAR Penalties After Doctor Hides Assets

Taxpayers can’t turn a blind eye to their IRS filing requirements and expect to avoid willful FBAR penalties. A recent decision from the United States District Court for the Eastern District of Michigan shows that when an anesthesiologist tried to… Read More
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US Sanctions Create FBAR Problems for Irani Immigrants

International sanctions made it hard for two Irani immigrants to transfer proceeds from the sale of their home. But the U.S. District Court in Oregon said that what they did next created FBAR problems resulting in willful FBAR penalties that no jury… Read More
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Harvard Professor Struggles to Defend Against Criminal Tax and FBAR Charges

If you are facing criminal FBAR charges for failing to disclose your foreign financial accounts, you and your tax attorney may need to get creative in crafting your defense. But as one recent criminal tax case from Massachusetts shows, creativity doe… Read More
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FBAR Penalty Calculations: Does the IRS Have to Show its Work?

When the IRS imposes penalties, it can sometimes seem as though the number is plucked from the air. But when an FBAR penalty case goes to trial, the IRS is required to prove the amount of its penalty complied with the law. However, a now-familiar cas… Read More
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Foreign Mutual Funds Lead to Willful Penalties for FBAR Filing Error

Sometimes, the interest earned through foreign mutual funds and investment accounts can result in income taxpayers don’t realize they have. These earnings are often reinvested automatically. If you and your accountant are not careful, an error in d… Read More
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