» FBAR

Why would you file a lawsuit against the IRS just to turn around and ask the District Court to dismiss it? A combination of impatience, new precedent, and personality changes left a Plaintiff looking for a way out of the Federal Court of Claims. Inte… Read More

Is there ever a good reason to hide something from the IRS? A recent opinion from the U.S. Federal Circuit Court of Appeals suggests that even the best of reasons won’t matter if a taxpayer is later found to have willfully failed to file FBAR forms… Read More

How many penalties can the IRS assess for a single missed form? That was the question before the Ninth Circuit Court recently in United States v Boyd. At least where an accurate FBAR report was filed late, the Court ruled that the one form and one vi… Read More

Many retired U.S. taxpayers don’t owe taxes at the end of the year. If their income from pre-tax retirement accounts and Social Security is offset by medical expenses or other allowable deductions, they may not have enough income to report, or any… Read More

What opportunity should you have to dispute an IRS penalty before it is assessed? Should you be able to take the government to court? What about an administrative hearing by the IRS Appeals Office? In a recent motion to dismiss a taxpayer’s complai… Read More

Can the IRS assess penalties for willful FBAR violations if the taxpayer didn’t mean to lie to the government or hide assets? In a second opinion, one federal judge in Pennsylvania has ruled that a drug company’s CEO owed more than $1 million in… Read More

If you decide to take advantage of more favorable terms and interest rates in foreign financial accounts, you may not realize how significantly those investment choices may complicate your tax filing requirements. Failing to file annual FBAR reports… Read More

If you have a complicated banking situation, including business entities and shared accounts with non-U.S. taxpayers, it may not be clear when you have a financial interest in foreign bank accounts that requires disclosure under the IRS regulations r… Read More