Money Laundering 101
Over the years, some clients and advisors have asked us about how to detect possible money laundering activities. To do so, an explanation of the basics is required. Money laundering is the process in which
Consequences of Filing False Streamlined Filings
The IRS Streamlined Domestic Offshore Program (“SDOP”) allows eligible U.S. Taxpayers who failed to disclose foreign financial accounts to voluntarily disclose their conduct to the IRS and pay a reduced penalty. However, to be eligible
Implications of United States v. Horowitz: Reckless = Willful?
In a recent court case, a court found that “willfulness” in the context of civil FBAR penalties is satisfied by recklessness and does not require disregard of a known legal duty. In United States
The IRS’ Complex Statute of Limitations
An IRS tax audit can be expensive and stressful. That is why is always important to check whether the IRS statute of limitations has expired for the audit. The expiration of the statute of limitations
Willful FBAR Penalties
U.S. Citizens who have a financial interest in or signature authority over foreign bank accounts that hold an aggregate amount greater than $10,000 are required to report the accounts to the IRS each year by