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Tax Law’s Two Definitio…

Tax Law’s Two Definitions of Willfulness, and Why They are Different

The definitions of words in the U.S. tax code can be the difference between criminal convictions and financial consequences. Most taxpayers would assume that one word in that code would have one meaning. But when it comes to the definitions of willfu… Read More
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Categories: Tax / IRS Penalties
Domino effect in business.

IRS Eclipses Record FBAR Penalties in New Tax Fraud Lawsuit

A recent federal court tax fraud lawsuit against a woman and her deceased husband’s estate has set a new record for FBAR penalties exceeding over $119.6 million. Find out what the IRS says she and her husband did to deserve such a steep penalty. Hu… Read More
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Many coins of various cryptocurrencies

IRS Promises Guidance on Reporting Cryptocurrency on Your Tax Returns

Preparing your own tax returns is hard enough when you are a regular employee with standard deductions. But what about when some of your currency only exists digitally? What do you need to know about reporting cryptocurrency on your tax returns? Will… Read More
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Categories: Tax / IRS Penalties
IRS Tax form 1040

IRS Voluntary Disclosure Can Promise Tax Fraud and Heavy FBAR Penalties

When taxpayers with foreign financial accounts take advantage of the IRS voluntary disclosure practice, they know that mistakes have been made, and that penalties will follow.  But they probably don’t think of themselves as “tax criminals”. Th… Read More
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Categories: Tax / IRS Penalties
The Ambassador Bridge linkink Detroit, Michigan, USA with Windsor, Ontario, Canada. The national flags of the USA and of Canada are notable in the foreground.

Court Tells U.S. Taxpayer Living Abroad, Pay First, Sue Second

If you are a foreign resident but a U.S. taxpayer, it can be especially difficult to find the right way to challenge an unfair tax assessment. You may question if internal IRS appeals are enough, or whether you have the right to refuse payment and su… Read More
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Categories: Tax / IRS Penalties
Hand holding U.S. passport

U.S. Tax Court Can Now Hear Tax Passport Certification Cases

Receiving a notice from the IRS is always stressful. When that document tells you that your passport could be affected, it can make you nervous to exercise your constitutional right to international travel. New changes to the U.S. Tax Court’s rules… Read More
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Categories: Tax / IRS Penalties
Woman and Man Facing Each Other Across Gap in Broken Bridge

Court Decision Widens Divide on Maximum Willful FBAR Penalties

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
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Whistleblower

Changes to Whistleblower Law Could Mean More FBAR Investigations

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
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U.S. Supreme Court May Rule on FBAR

Resolving the FBAR Penalty Conflict: Will Taxpayers Have to Pay 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
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Disintegrating Dollar Sign - Symbol of higher maximum willful FBAR penalties

Federal Court Says 2004 Law Raised Maximum Willful FBAR Penalties​

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
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