» Tax / IRS Penalties

When family money is passed down through the generations, it isn’t always clear who owns the accounts, or who is required to disclose them to the IRS. A recent case from the Federal Court of Claims considers whether an undocumented, informal trust… Read More

Every year, millions of Americans file their taxes using TurboTax or another commercial tax prep software. The hope is that these programs will make sure their taxes are done correctly and avoid penalties or even an IRS audit. However, one recent cas… Read More

A trust can be a useful wealth management tool to reduce tax obligations, and ensure beneficiaries receive their intended assets. However, when that trust is held overseas, the IRS requires extra tax returns from both owners and beneficiaries to make… Read More

The question of just how expensive a willful penalty for failing to report foreign financial accounts has been making its way through the federal court systems. Now, the Second Circuit has issued a split opinion that shows just how divided judges are… Read More

Can the government restrict your ability to travel overseas if you don’t pay your taxes? Is the 2015 FAST Act’s passport certification process constitutional? One doctor challenged the law, but he may have filed his lawsuit a bit too soon. 20 Yea… Read More

Why would you file a lawsuit against the IRS just to turn around and ask the District Court to dismiss it? A combination of impatience, new precedent, and personality changes left a Plaintiff looking for a way out of the Federal Court of Claims. Inte… Read More

Is there ever a good reason to hide something from the IRS? A recent opinion from the U.S. Federal Circuit Court of Appeals suggests that even the best of reasons won’t matter if a taxpayer is later found to have willfully failed to file FBAR forms… Read More

How many penalties can the IRS assess for a single missed form? That was the question before the Ninth Circuit Court recently in United States v Boyd. At least where an accurate FBAR report was filed late, the Court ruled that the one form and one vi… Read More