» FBAR

It can sometimes feel like an IRS audit or tax assessment can take forever, leaving taxpayers to wonder how long the IRS has to sue for FBAR penalties. A recent case coming out of the federal District Court in the Eastern District of New York shows t… Read More

The penalties imposed for failure to file a Foreign Bank Account Reporting form (FBAR) can be substantial. The IRS has many mechanisms to collect on those debts. If you have received a notice of collection efforts, can you request a collection due pr… Read More

They say that nothing is certain except death and taxes. A recent decision by the United States District Court for the Southern District of New York says, between the two, taxes win. The judge granted the IRS authority to collect FBAR penalties from… Read More

Penalties for willful failure to file reports of foreign financial accounts – commonly called FBARs – are some of the highest civil penalties the government can impose. But until now, no court had been willing to say those fines were excessive. I… Read More

The Ninth Circuit – known as one of the most taxpayer friendly of the federal circuit courts – has joined many other courts in holding that reckless violations of the Bank Secrecy Act were sufficient to uphold willful FBAR penalties. The Court af… Read More

There have been a lot of cases in the last several years defining willfulness in the context of failures to file FBAR forms with the IRS. But a recent decision from the Northern District of California addresses the issue slightly differently. Instead… Read More

The Sixth Circuit Court of Appeals, which controls much of the Midwest, has joined several other appellate courts to confirm that recklessness is enough to support willful penalties for FBAR filing failures. Reviewing the case of United States v. Kel… Read More

Expatriates often have a foot in two (or more) countries, physically and financially speaking. This can make it difficult to understand their U.S. tax filing requirements. Add to that the extra requirement of filing FBARs disclosing foreign financial… Read More