» FBAR
The Case(s) for Lower Willful FBAR Penalties
October 24th, 2018
Not disclosing your foreign bank accounts to the IRS can quickly become a costly mistake. But has the IRS been imposing penalties for failure to file FBAR forms that are even higher than it should? There is a case to be made for lower willful FBAR pe…
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Is the IRS Breaking its Own Rules for Willful FBAR Penalties?
October 10th, 2018
The Secretary of Treasury and the Internal Revenue Service (IRS) are controlled by a number of laws and regulations that set the rules for issuing taxes, fines, and penalties against U.S. taxpayers. But when the law related to willful FBAR penalties…
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Can an IRS Case History Prove Non-Willfulness?
September 24th, 2018
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…
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IRS Says FBAR Penalty Is Not a Fine Under Eighth Amendment
September 11th, 2018
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…
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What Do Willful Violations of FBAR Reporting Requirements Look Like?
August 17th, 2018
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…
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PFIC 101: How to Avoid PFIC Excess Distribution Interest Penalties
June 25th, 2018
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…
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PFIC 101: How to Tell if You Have PFIC Stock Interests
June 11th, 2018
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…
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PFIC 101: Reporting PFIC Tax Obligations for Foreign Stockholders
May 24th, 2018
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…
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PFIC 101: What is a Passive Foreign Investment Company?
May 10th, 2018
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…
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Swiss Bank Concealment Scheme Results in Prison and FBAR Penalties
February 26th, 2018
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…
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