» Tax / IRS 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… Read More
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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… Read More
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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… Read More
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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… Read More
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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… Read More
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Categories: Tax / IRS Penalties
US Passport

National Taxpayer Advocate Calls Passport Revocation for Unpaid Taxes Unconstitutional

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
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Categories: Tax / IRS Penalties
Hourglass and calendar - How long can the IRS wait before imposing tax assessments?

How Long Can the IRS Wait Before Imposing Tax Assessments?

When taxpayers discover errors in their tax returns, or they learn they were supposed to file FBAR reports, the problem they uncover can sometimes span years. The larger these foreign financial accounts are, the quicker the unpaid taxes, penalties, a… Read More
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Switzerland Flag Piggy Bank

Swiss Bank Concealment Scheme Results in Prison and FBAR Penalties

Many foreign nationals do not realize the reporting and tax requirements imposed on them by the IRS. While it has been said ignorance of the law is no excuse, intentional tax avoidance can result in far more severe penalties, including prison and mil… Read More
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Exclamation Point Sign - Accountant Advice May Not Protect from FBAR Penalties

Wrong Answer on Schedule B Dooms Taxpayers' Attempt to Rely on Accountant's Tax Advice as Reasonable Cause to Avoid FBAR Penalties

Many American taxpayers and business owners use accountants or CPAs to prepare their taxes. Their involvement in the tax process may be as little as signing the return and cutting a check, without ever really considering their accountant’s advi… Read More
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$1 Million - FBAR penalty

Criminal Bribery Charges Lead to $1 Million FBAR Penalties

For many taxpayers, the failure to file reports of foreign financial accounts happens by accident, or at least inadvertently. Even many penalties issued for willful violations are the result of a taxpayer’s negligence rather than any complex ta… Read More
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