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Do You Have to Report Your Business’s Foreign Financial Accounts on Your FBAR?
September 10th, 2020
If you are operating a business with accounts overseas, it may make sense to maintain foreign financial accounts in those countries to make doing business easier. But as a business owner, choosing to open bank accounts in other countries may create t…
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Non-Willful FBAR Penalties Capped Per Year, Not Account, Court Says
August 10th, 2020
Could the way you do your banking affect how much you pay in IRS filing penalties? Until recently, the answer was universally yes. Now a federal district court judge in Texas has said that for non-willful FBAR penalties, Congress set the cap per year…
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Married Spouses’ Willful FBAR Penalties Are Double, Treasury Department Says
July 10th, 2020
Most married couples manage their money together. They may hold accounts jointly, or each keep their names on their own assets. But according to a recent complaint filed by the United States Secretary of Treasury, even keeping accounts in one spouse…
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IRS Says Widow Committed Willful FBAR Violations Just by Signing Tax Returns
June 24th, 2020
In many relationships, one spouse may handle all the financial affairs of the household. But what happens when that spouse dies? Can a widow (or widower) be assessed a willful FBAR penalty just for signing tax returns prepared by her spouse and a CPA…
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How Courts Calculate Willful FBAR Penalties
June 10th, 2020
If things have gone wrong and you find yourself and your overseas bank accounts the subject of an IRS audit, you may feel like you are preparing for the worst. But what is the worst? How do the IRS and tax courts calculate willful FBAR penalties when…
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Federal Circuit Court Weighs In on Willful FBAR Penalty Cap Issue
December 10th, 2019
The question of just how expensive an IRS willful FBAR penalty can be has been making its way through trial courts across the country for more than a year. Now the first of those cases are coming up on appeal. As the Federal Circuit Court weighs in o…
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Categories: FBAR
FBAR Willfulness Decision is Up to the Jury, Court Says
September 24th, 2019
The difference between a willful and non-willful FBAR penalty against a U.S. taxpayer can be thousands, and sometimes millions of dollars. But how can the IRS know what was going on in your head, and whether your failure to file was on purpose? A rec…
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IRS Eclipses Record FBAR Penalties in New Tax Fraud Lawsuit
September 10th, 2019
A recent federal court tax fraud lawsuit against a woman and her deceased husband’s estate has set a new record for FBAR penalties exceeding over $119.6 million. Find out what the IRS says she and her husband did to deserve such a steep penalty. Hu…
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Do You Need to Report Cryptocurrency on Your FBAR?
August 26th, 2019
Where does an entirely virtual financial institution exist: on your phone, in a server-farm somewhere? Could the location of the founding company turn your Bitcoin wallet into a foreign financial institution? If so, you may need to report cryptocurre…
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Categories: FBAR
Would You Rather Pay Many Smaller FBAR Penalties, or One Big One?
July 10th, 2019
When tax attorneys came together at the New York University Tax Controversy Forum, everyone was talking about recent cases over the upper limit of willful FBAR penalties on a single account. But for one speaker, the question was which was worse: bein…
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Categories: FBAR
