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If you have been assessed a civil penalty for willful FBAR violations, you may be wondering whether the IRS has the final say. Find out how to challenge a penalty for willful FBAR violations, and how the courts will decide whether or not you have to… Read More

The Foreign Account Tax Compliance Act (FATCA) was designed to help the U.S. government track down undisclosed taxable assets overseas. Many say enforcement has been ineffective so far. Now U.S. prosecutors are claiming their first FATCA criminal con… Read More

What does it mean to willfully fail to file foreign financial account reports or make false statements on your tax returns? Can you willfully violate a rule you didn’t know existed? And if you do, how much should you be charged? These aren’t new… Read More

Now that the OVDP is no longer available, what will taxpayers with undisclosed foreign assets do? The U.S. Department of Treasury has announced a new voluntary disclosure practice as an option for those trying to avoid possible criminal consequences.… Read More

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… Read More

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… Read More

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… Read More

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… Read More