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Redacted IRS Case History

Can an IRS Case History Prove Non-Willfulness?

When you are facing willful FBAR penalties, you need all the help you can get to prove that your failure to file reports of foreign financial accounts was not intentional or reckless. But could the IRS’s own records help you win your case? Can… Read More
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U.S. Constitution

IRS Says FBAR Penalty Is Not a Fine Under Eighth Amendment

Willful FBAR penalties can quickly add up to hundreds of thousands of dollars. But are those penalties an unconstitutional fine under the Eighth Amendment? In a recent filing in the United States Court of Federal Claims, the government said the amoun… Read More
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IRS Agent Showing Red Card for Willful Violation of FBAR Reporting Requirements

What Do Willful Violations of FBAR Reporting Requirements Look Like?

The difference between penalties for willful violations of FBAR reporting requirements and non-willful violations could be hundreds of thousands of dollars, federal criminal charges, and prison time. But it can be hard for taxpayers to know what to e… Read More
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Using Smartphone as Calculator - Determining PFIC Excess Distribution Interest Penalties

PFIC 101: How to Avoid PFIC Excess Distribution Interest Penalties

Once U.S. taxpayers identify passive foreign investment company assets in their portfolio, the next logical step is to minimize the tax consequences connected to those assets. At the top of the list is finding a way to avoid PFIC excess distribution… Read More
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Photo of Woman Pointing with Pen to PFIC stock interests Line Item on Printout

PFIC 101: How to Tell if You Have PFIC Stock Interests

It may seem easy to know whether a U.S. taxpayer has stock interests overseas. You may think that you will cross that bridge if and when you decide to invest in a foreign investment company. But you may have PFIC stock interests you don’t recog… Read More
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PFIC - Financial Data on Global Map

PFIC 101: Reporting PFIC Tax Obligations for Foreign Stockholders

When U.S. taxpayers own stock in foreign mutual funds and other investment companies, they may know the income from those assets need to be reported to the IRS. They may even know they can be taxed on that foreign income. But for many U.S. shareholde… Read More
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Report of Passive Foreign Investment Company

​PFIC 101: What is a Passive Foreign Investment Company?

When U.S. taxpayers own or have interest in foreign assets overseas, it can raise reporting and tax consequences they don’t expect. FBARs and foreign asset reporting requirements can leave taxpayers worrying about what other legal obligations they… Read More
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Switzerland Flag Piggy Bank

Swiss Bank Concealment Scheme Results in Prison and FBAR Penalties

Many foreign nationals do not realize the reporting and tax requirements imposed on them by the IRS. While it has been said ignorance of the law is no excuse, intentional tax avoidance can result in far more severe penalties, including prison and mil… Read More
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Exclamation Point Sign - Accountant Advice May Not Protect from FBAR Penalties

Wrong Answer on Schedule B Dooms Taxpayers' Attempt to Rely on Accountant's Tax Advice as Reasonable Cause to Avoid FBAR Penalties

Many American taxpayers and business owners use accountants or CPAs to prepare their taxes. Their involvement in the tax process may be as little as signing the return and cutting a check, without ever really considering their accountant’s advi… Read More
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$1 Million - FBAR penalty

Criminal Bribery Charges Lead to $1 Million FBAR Penalties

For many taxpayers, the failure to file reports of foreign financial accounts happens by accident, or at least inadvertently. Even many penalties issued for willful violations are the result of a taxpayer’s negligence rather than any complex ta… Read More
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