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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…
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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…
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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…
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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…
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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…
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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…
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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…
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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…
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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…
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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…
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