Taxpayer’s FBAR WIN: “Willful” Penalty over $9.8 Million for Mere Signature Authority — Removed Entirely

Today’s post involving the case of Jonathan Zuhovitzky presents some important takeaways:  The IRS can get very aggressive when it comes to assessing “willful” FBAR penalties. We see this trend is on the rise. A diligent representative, however, can get the IRS to settle an FBAR matter that is favorable to the taxpayer.  It takes … Continue reading Taxpayer’s FBAR WIN: “Willful” Penalty over $9.8 Million for Mere Signature Authority — Removed Entirely

REMINDER: Wondering if You (or Your Clients) Need to File an FBAR or Have Been Preparing Them Correctly?

Please spread the word and share this news. I will be making FBAR matters simple in a cost-effective live online training session along with my colleague, Jimmy Sexton, LL.M. a fellow international tax expert. Whether you are preparing your own FBARs or those of your clients, the truth is that some FBAR situations are simple … Continue reading REMINDER: Wondering if You (or Your Clients) Need to File an FBAR or Have Been Preparing Them Correctly?

Want Protection from Criminal Prosecution for Tax Noncompliance? IRS Provides Only One Way

As many will remember, the Offshore Voluntary Disclosure Program (OVDP) closed on September 28 2018 with the promise that the Internal Revenue Service (IRS) would issue new guidance on voluntary disclosures made after that date.  The guidance arrived on November 20 2018 in the form of a 5-page Memorandum (IRS Memorandum LB&I-09-1118-014) (“Memorandum”) by the … Continue reading Want Protection from Criminal Prosecution for Tax Noncompliance? IRS Provides Only One Way

No IRS! The Sky is NOT the Limit….MAJOR FBAR WIN! Penalty is Per FBAR Form, Not Per Account

As all my readers know, the Bank Secrecy Act (BSA) has been requiring US taxpayers to report certain foreign financial accounts and retain detailed records about them.  Failing to file or to properly report all foreign accounts on the notorious “FBAR” (FinCEN Form 114, Report of Foreign Bank and Financial Accounts) can result in very high … Continue reading No IRS! The Sky is NOT the Limit….MAJOR FBAR WIN! Penalty is Per FBAR Form, Not Per Account

MERRY CHRISTMAS: FATCA Drops Coal on the Doorstep of Americans Abroad

Merry Christmas to all of my readers and followers who celebrate this special time of year. I hope the joy of the season will follow you into the New Year. Sadly, Christmas won’t be merry for many Americans abroad who are ensnared in the grip of “FATCA,” the notorious “Foreign Account Tax Compliance Act”.  Briefly, … Continue reading MERRY CHRISTMAS: FATCA Drops Coal on the Doorstep of Americans Abroad

CONFUSED? FinCEN Blows it….FBAR Due Date Now Extended Till October 31 2020

On October 14, the Financial Crimes Enforcement Network (FinCEN) caused a lot of confusion for taxpayers and their advisors concerning the filing due date for foreign (non-US) financial accounts.  An incorrect posting was issued by FinCEN about the 2020 deadline to file Form 114, Report of Foreign Bank and Financial Accounts, commonly known as the … Continue reading CONFUSED? FinCEN Blows it….FBAR Due Date Now Extended Till October 31 2020

Seriously? IRS Assesses US$5.1 Million FBAR Penalty for “Signature Authority”

I have been keeping readers up to date with the current controversy surrounding imposition of an FBAR penalty for “willful” violations – is it limited to a $100,000 cap or can the penalty, if greater, be assessed at 50% of the value of the unreported account? More detailed background on this issue is available at my … Continue reading Seriously? IRS Assesses US$5.1 Million FBAR Penalty for “Signature Authority”