Tag: foreign accounts

The Sky’s the Limit: FBAR Penalty Win for IRS – New Case Upholds 50% of Account Balance

I have been keeping readers up to date with the current controversy surrounding imposition of an FBAR penalty for “willful” violations.  Two courts have limited the FBAR “willfulness” penalty to $100,000 because the Department of Treasury did not update the relevant regulations to match the statute as revised by Congress in 2004.  Essentially the dispute … Continue reading The Sky’s the Limit: FBAR Penalty Win for IRS – New Case Upholds 50% of Account Balance →

The FATCA Goose Lays a Rotten Egg: Treasury Watchdog Lambasts IRS & US Supreme Court Denies Relief

I have blogged extensively about the “Foreign Account Tax Compliance Act” (FATCA) in the past.  Most of my readers know that FATCA was enacted in 2010 but has taken years to implement. The law requires foreign (non-US) financial institutions (FFIs) to report financial accounts owned by US persons (including through entities) to the Internal Revenue … Continue reading The FATCA Goose Lays a Rotten Egg: Treasury Watchdog Lambasts IRS & US Supreme Court Denies Relief →

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” →