» 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

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

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

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

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

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

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

How large a penalty is too large, constitutionally speaking? Many people are shocked to learn that the maximum amount for a willful FBAR penalty is one half the balance of the account at the end of the reporting year. This can easily add up to millio… Read More