Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
On September 19, 2025, the U.S. District Court for the Northern District of Texas upended IRS FBAR enforcement in United States v. Sagoo (No. 4:24-cv-01159, N.D. Tex. 2025). Sharnjeet Sagoo, a U.S. taxpayer with international ties, faced over $1 million in penalties for alleged willful failures of the Bank Secrecy Act requirement to report foreign … Continue reading The Sagoo Case: FBAR’s Reckoning In A Globalized World
On May 23, a decision (Decision) by the Belgian Data Protection Authority (BDPA) now prohibits the Belgian tax authorities (the defendant in this case) from transferring to the Internal Revenue Service (IRS) the personal data of Belgian “Accidental Americans” (and likely other US persons with accounts in Belgium) pursuant to the ”FATCA” Intergovernmental Agreement between … Continue reading Belgium Fights Back! No FATCA Info to IRS – Deep Dive the Belgian Decision
It’s been no secret that virtual currency has been in the crosshairs of the Internal Revenue Service (IRS) for some time. Virtual currency is one of the IRS “campaigns” and criminal investigations related to crypto have already started. The IRS has been sending taxpayers “educational” letters to remind them and warn them of their tax … Continue reading The Times They Are a Changin’ – FBAR Reporting of Virtual Currency Foreign Accounts
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