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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
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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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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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Mirelis Customers Face OVDP Fines After Non-Prosecution Settlement
September 5th, 2018
Customers of the Swiss financial and asset management company Mirelis Holdings, SA, may have known about changes happening at the company in recent years. But what they may not have realized is that a recent non-prosecution settlement between the fir…
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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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