» FBAR
California Case Signals Bigger Non-Willful FBAR Penalties to Come
June 10th, 2019
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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The Muddier Waters of Willful FBAR Penalty Maximums
April 25th, 2019
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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Categories: FBAR
What to Do if You Receive a Soft Letter from the IRS
March 28th, 2019
Enforcement at the IRS is getting tighter. Now that the Offshore Voluntary Disclosure Program is closed, taxpayers with foreign financial accounts are facing the possibility of higher penalties and tighter scrutiny of their offshore assets. One metho…
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How to Challenge a Penalty for Willful FBAR Violations
March 1st, 2019
If you have been assessed a civil penalty for willful FBAR violations, you may be wondering whether the IRS has the final say. Find out how to challenge a penalty for willful FBAR violations, and how the courts will decide whether or not you have to…
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Categories: FBAR
Court Decision Widens Divide on Maximum Willful FBAR Penalties
January 31st, 2019
What does it mean to willfully fail to file foreign financial account reports or make false statements on your tax returns? Can you willfully violate a rule you didn’t know existed? And if you do, how much should you be charged? These aren’t new…
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Treasury Dept. Announces New Voluntary Disclosure Practice
January 21st, 2019
Now that the OVDP is no longer available, what will taxpayers with undisclosed foreign assets do? The U.S. Department of Treasury has announced a new voluntary disclosure practice as an option for those trying to avoid possible criminal consequences.…
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Government Watchdog Says FBAR Database Lacks Quality Controls
December 28th, 2018
When the IRS singles you out for an audit or FBAR investigation, you assume that the process will have certain controls to be sure things are done properly. But a recent report by the Government Accountability Office, a government watchdog agency, re…
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Categories: FBAR
Changes to Whistleblower Law Could Mean More FBAR Investigations
December 14th, 2018
Whistleblowers have long been a strategic part of how the IRS investigates potential tax fraud cases. Now a change to whistleblower law will mean those who disclose unreported international accounts could receive rewards based on FBAR penalties and c…
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Resolving the FBAR Penalty Conflict: Will Taxpayers Have to Pay More?
November 26th, 2018
The federal district courts and the court of claims have come down on opposite sides and created an FBAR penalty conflict. Could the issue be headed for the Supreme Court? Or will U.S. taxpayers with financial accounts overseas end up paying more reg…
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Federal Court Says 2004 Law Raised Maximum Willful FBAR Penalties
November 9th, 2018
Three federal district courts have said the IRS is breaking its own rules by imposing penalties beyond a Treasury Department regulation. But the federal Court of Claims says a 2004 law raised the maximum willful FBAR penalties. That decision could co…
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