New FBAR “Willful” Penalty Case: But You Can’t Blame the IRS!  

I don’t have much to say about this case, simply because not much needs to be said. In United States v. Gentges (USDC SDNY Dkt. 7:18-cv-07910), the Government is bringing a lawsuit to collect a “willful” FBAR penalty for the tax year 2007 in an amount close to USD904,000. The penalties relate to two Swiss bank accounts … Continue reading New FBAR “Willful” Penalty Case: But You Can’t Blame the IRS!  

OVDP Ending / IRS To Announce New Procedures

The Internal Revenue Service (IRS) reminded taxpayers yesterday that they have until September 28 to apply for the Offshore Voluntary Disclosure Program (OVDP). In March, the IRS announced the program would end on the 28th of this month. The IRS has made clear that it will continue to hold taxpayers with undisclosed offshore holdings accountable after … Continue reading OVDP Ending / IRS To Announce New Procedures

Kotholos – New Case Shows IRS Aggression in Asserting FBAR “Willful” Penalty

I have been blogging recently (here and here) about the IRS’ aggressive stance in determining what constitutes a taxpayer’s “willful” failure to file an FBAR and the fact that mounting court cases show the judiciary is buying in to the IRS’ position.  Courts appear to be more easily upholding a finding of “willfulness” when it … Continue reading Kotholos – New Case Shows IRS Aggression in Asserting FBAR “Willful” Penalty

Tax Primer: US Expats & Foreigners

Everything you need to know about US tax is right here at your fingertips!  My primer provides information for overseas Americans and green card holders on US tax obligations including Income Tax, Estate Tax and Gift Tax as well as IRS reporting requirements and State income tax. It also provides detailed information for foreign individuals … Continue reading Tax Primer: US Expats & Foreigners

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”