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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… Read More

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… Read More

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… Read More

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… Read More

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… Read More

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… Read More

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… Read More

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… Read More