Mr. FBAR Gets Bolder in Toth – “Deemed Willfulness” for FBAR Violation
Today’s blog post looks again at the Report of Foreign Financial Accounts (Form 114), the well-known “FBAR”. It examines a case of first impression when it comes to finding a “willful” FBAR violation. Before delving into the case, I provide readers with a quick introduction to Mr. FBAR. The FBAR has its genesis in the … Continue reading Mr. FBAR Gets Bolder in Toth – “Deemed Willfulness” for FBAR Violation