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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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What to Do if You are Certified for Passport Revocation by the IRS
July 25th, 2018
The IRS has started to send certification of individual taxpayers with seriously delinquent tax debt to the State Department for passport consequences under the FAST Act. Your options to appeal this determination are limited. Know what to look for an…
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Categories: Tax / IRS Penalties
National Taxpayer Advocate Calls Passport Revocation for Unpaid Taxes Unconstitutional
July 10th, 2018
Can the IRS take away your right to travel without advanced notice? The National Taxpayer Advocate says the passport revocation program created by Congress in 2016 — which authorizes passport revocation for unpaid taxes — may be unconstitutional…
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Categories: Tax / IRS Penalties
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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