Second Court Bars IRS from Assessing FBAR “Willful” Penalty in Excess of $100,000

Another court just slammed the Internal Revenue Service (IRS), limiting the “willful” FBAR penalty to $100,000. Another taxpayer victory took place last week in United States v. Wadhan, (Civil Action No. 17-CV-1287-MSK District Court, District of Colorado July 18, 2018). The Wadhan’s failed to file or filed inaccurate so-called FBARs for 2008, 2009, and 2010. … Continue reading Second Court Bars IRS from Assessing FBAR “Willful” Penalty in Excess of $100,000 →

Court Slams IRS: Can’t Assess More Than $100,000 “Willful” FBAR Penalty

The Internal Revenue Service (IRS) must be fuming over the recent court decision in United States v. Colliot (W.D. Texas, Austin Division, Case No. AU-16-CA-01281-SS). The case was initiated by the US Government to reduce to judgment outstanding civil penalties assessed against Ms. Colliot for her “repeated and willful failures to timely file” an FBAR for the … Continue reading Court Slams IRS: Can’t Assess More Than $100,000 “Willful” FBAR Penalty →

FBAR “Willful” Penalty: New Case, Taxpayer “Charged With Knowledge”

I blogged recently about the fact that mounting court cases have given the stamp of approval for the Government to meet a lower “burden of proof” in demonstrating that a taxpayer “willfully” failed to file an FBAR. The “burden of proof” refers to which party is responsible for putting forth evidence and, the level of evidence … Continue reading FBAR “Willful” Penalty: New Case, Taxpayer “Charged With Knowledge” →

Passport Revocation Update: Over 436,000 Taxpayers Meet “Certification” Criteria

Many of my readers already know that one’s US passport is in serious jeopardy if a taxpayer has what is called “seriously delinquent tax debt”. First, some brief background on the law and how it particularly affects Americans living and working overseas. I’ll then provide the latest statistics on the passport enforcement efforts since the … Continue reading Passport Revocation Update: Over 436,000 Taxpayers Meet “Certification” Criteria →

US Tax Perils of International Community Property

US tax liabilities and requirements to file US tax and information returns are impacted by community property laws that exist in many foreign countries across the globe. Today’s blog post will examine some of these issues and set the stage for upcoming posts dealing with community property in the international context and how it affects … Continue reading US Tax Perils of International Community Property →