» FBAR

Whenever the IRS issues an assessment, it starts a clock. Unless taxpayers work quickly to address the issue, they will begin to accrue penalties and interest on that assessment. But what happens if you take the IRS to court over improper FBAR penalt… Read More

Is mistakenly failing to file a Report of Foreign Financial Accounts (FBAR) one violation of the Bank Secrecy Act, or several? Whether non-willful FBAR penalties apply per form or per account has become the next big debate among tax attorneys and fed… Read More

When U.S. taxpayers do banking overseas, they don’t often choose an investment strategy based on the number of accounts they will hold. However, the IRS maintains that it can assess penalties for multiple FBAR violations in one tax year. That could… Read More

When family money is passed down through the generations, it isn’t always clear who owns the accounts, or who is required to disclose them to the IRS. A recent case from the Federal Court of Claims considers whether an undocumented, informal trust… Read More

Every year, millions of Americans file their taxes using TurboTax or another commercial tax prep software. The hope is that these programs will make sure their taxes are done correctly and avoid penalties or even an IRS audit. However, one recent cas… Read More

There’s an old saying that nothing is inevitable but death and taxes. But in a fight between the two, which one wins? If a person dies before paying off an assessment, can the IRS collect non-willful FBAR penalties from the deceased taxpayer’s es… Read More

The question of just how expensive a willful penalty for failing to report foreign financial accounts has been making its way through the federal court systems. Now, the Second Circuit has issued a split opinion that shows just how divided judges are… Read More

Many taxpayers facing audits over their foreign financial accounts say they relied on their CPA or accountant and didn’t know they had a duty to file FBAR reports. But when the taxpayer was a CPA himself, his claims of ignorance weren’t enough to… Read More