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High-Income Taxpayers: Get Your Taxes Filed On Time, or Else, IRS Says
February 23rd, 2021
Individuals and households earning more than $100,000 often have more complicated tax situations than their lower-earning counterparts. That could be especially true this year, as many wage-based employees are finding themselves working from home and…
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Categories: IRS Debt Collection
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IRS Tax Installment Agreements: What You Need to Know
February 8th, 2021
The amount taxpayers owe the IRS for unpaid taxes and penalties can add up quickly. Past-due penalties and statutory interest can turn even a modest unpaid tax debt into a significant problem, even for couples making a comfortable living. IRS tax ins…
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Categories: IRS Debt Collection
IRS Says Due Process Only Requires Written Response, Not a Hearing
January 22nd, 2021
What opportunity should you have to dispute an IRS penalty before it is assessed? Should you be able to take the government to court? What about an administrative hearing by the IRS Appeals Office? In a recent motion to dismiss a taxpayer’s complai…
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Court Finds Drug CEO’s FBAR Violations Willful, Even if Unintentional
January 8th, 2021
Can the IRS assess penalties for willful FBAR violations if the taxpayer didn’t mean to lie to the government or hide assets? In a second opinion, one federal judge in Pennsylvania has ruled that a drug company’s CEO owed more than $1 million in…
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IRS Ignores Reasonable Cause Statements in Assessing Foreign Trust Account Reporting Penalties, Website Says
December 29th, 2020
Recent changes to the IRS website acknowledged an existing policy to assess penalties for failure to file Form 3520 regarding foreign trust assets without considering taxpayer-provided reasonable cause statements. The website warns that taxpayers wil…
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Judge Cancels $3.2 Million in Foreign Trust Reporting Penalties
December 11th, 2020
If you are the owner or beneficiary of a foreign trust, you must disclose that asset, and any distributions you receive from it to the government every year. Failure to comply with the IRS reporting requirements can add up to steep penalties, and eve…
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Categories: Tax / IRS Penalties
Fourth Circuit Adopts “Recklessness” Standard For Willful FBAR Violation and Rejects $100,000 Willfulness Penalty Cap Argument.
November 24th, 2020
If you decide to take advantage of more favorable terms and interest rates in foreign financial accounts, you may not realize how significantly those investment choices may complicate your tax filing requirements. Failing to file annual FBAR reports…
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When Do You Have a Financial Interest in Foreign Bank Accounts for FBAR Filings?
November 11th, 2020
If you have a complicated banking situation, including business entities and shared accounts with non-U.S. taxpayers, it may not be clear when you have a financial interest in foreign bank accounts that requires disclosure under the IRS regulations r…
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Can You Plead the Fifth Amendment on FBAR Filings?
October 26th, 2020
After spending years trying to hide money in a “secret account” in Switzerland, one couple was assessed civil willful FBAR penalties after they filed a report that simply said “Fifth Amendment”. The tactic raises the question, can you plead t…
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What Are the FBAR Reporting Requirements for U.S. Citizens Living Overseas?
October 12th, 2020
If you are an American citizen whose work, family, or lifestyle have sent you to live overseas, you may wonder whether you are still required to file U.S. tax returns or disclose your foreign assets. A recent complaint filed by the IRS in the United…
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Categories: FBAR
