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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…
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…
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…
Dollar Folded into Arrow Pointing Down - Lower FBAR Penalties

The Case(s) for Lower Willful FBAR Penalties

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…
Woman reviewing willful FBAR penalties

Is the IRS Breaking its Own Rules for Willful FBAR Penalties?

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…
Redacted IRS Case History

Can an IRS Case History Prove Non-Willfulness?

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…
U.S. Constitution

IRS Says FBAR Penalty Is Not a Fine Under Eighth Amendment

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…
Swiss bank

Mirelis Customers Face OVDP Fines After Non-Prosecution Settlement

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…
IRS Agent Showing Red Card for Willful Violation of FBAR Reporting Requirements

What Do Willful Violations of FBAR Reporting Requirements Look Like?

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…
U.S. Passports

What to Do if You are Certified for Passport Revocation by the IRS

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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