Interesting 2023 Foreign Account Cases
Foreign Account/FBAR confusion: In Kurotaki v. United States, 132 AFTR2d 2023-6138, a Hawaii federal district court determined that a U.S. green card holder who lived in Japan and spoke no...
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IRS FBAR Penalties Are Now Unmitigated
The Internal Revenue Service will no longer reduce the penalty for taxpayers who non willfully fail to file Reports of Foreign Bank and Financial Accounts (FBAR or FinCen 114), according...
REPORTING FOREIGN ASSETS & ACTIVITIES: REQUIREMENTS AND CHALLENGES: Complimentary CPE Presentation
...FBAR penalties Summary of most common international tax reporting forms RSVP: https://www.wgcpas.com/reporting-foreign-assets-activities-requirements-and-challenges/ CPE: 1.5 NJ credits WHEN: Monday, April 24th, 2023 Networking & Snacks: 6:00-6:30 PM CPE Seminar: 6:30-8:00 PM...
Foreign Gift Received: Form 3520 Penalties Eliminated in New Court Case
...determined that the IRS could only penalize taxpayers once per-form (instead of per-account) per-year for failing to file a Report of Foreign Bank and Financial Accounts (or “FBAR”). The Wrzesinski...
Rare Supreme Court Ruling Favors Taxpayers!
...FBAR. The statute (31 U.S.C. §5321(a)(5)(B)) prescribes a civil penalty of up to $10,000 for a non-willful violation of any provision of the FBAR filing requirement (unless due to reasonable...
High Penalties for failure to file an FBAR: Not Really Enforced (yet)?
...If the aggregate value of the foreign financial accounts exceeded $10,000 at any time during the year, a ‘Foreign Bank Account Report’ (FBAR) must be filed. The FBAR is due...
New IRS FBAR Practice Unit
...for Late-Filed FBARs? Under the BSA, the IRS can assess civil penalties if a USP has an FBAR reporting obligation and fails to timely file a complete and accurate FBAR. ...
Recent Court Decision Shows Risks of IRS Streamlined Filing Compliance Procedures
...v. U.S., No. 21-1202T (Fed. Cl. Aug. 23, 2022). In Flint, the taxpayer failed to file FBARs regarding significant holdings in foreign accounts. After the taxpayer’s husband passed away, the...
Foreign pension accounts reporting on the FBAR
...reported on FBAR? Some practitioners take the position that these plans do not need to be reported on the FBAR. We disagree. A conservative approach would be to report it...
US Reporting of Foreign Retirement Accounts
Many clients contact our office regarding the failure to report their foreign retirement account. Such accounts need to be fully reported on an FinCen 114 (FBAR) and IRS Form 8938....
Specific Steps for Applying to the IRS Streamlined Foreign Offshore Procedures
...5471, and 8938. In addition, the applicant must file any delinquent FBAR forms for the past six years for which the FBAR filing requirement has passed. In order to ensure...
US Supreme Court to Rule on FBAR Penalties Case
The debate over FBAR penalties for non-willful failure to disclose all of an individual’s or business’ foreign bank accounts has reached the Supreme Court. The issue is whether the maximum...