Significant FBAR Penalties Upheld by Court
...in the account or the account number. The ruling seems to unfairly put at risk all taxpayers who on the Forms 1040 checked ‘no’ in the foreign account box on...
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Analysis: IRS New Disclosure Program
...eliminates the risk of criminal prosecution but there are many changes from the former OVDP. Some of the changes are procedural, such as no longer requiring the filing of required...
New Post-OVDP IRS Voluntary Disclosure Procedures Announced
...important. 2. PROCEDURE: The process begins with taxpayers requesting “preclearance” for participation from the IRS Criminal Investigation Division (which is similar to the old OVDP program), after which civil examiners...
New Jersey Enacts Tax Amnesty Bill
Enacted legislation requires the New Jersey Division of Taxation to establish a 90-day state tax amnesty period that ends no later than January 15, 2019. The Legislature had previously passed...
The TCJA and the Future of American Taxpayers
...charitable gifts. If you’re in such a scenario, then perhaps the most valuable year-end tax planning strategy is to accelerate charitable contributions before the end of 2018. One of the...
Federal District Court Holds that FBAR Penalties in Excess of $100,000 is Unlawful
...of Foreign Bank and Financial Accounts, commonly referred to as an FBAR, could not be penalized in excess of the $100,000 regulatory maximum even though the relevant statute allows higher...
2018 ABA COMMENTS ON THE OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS
...of Foreign Bank and Financial Accounts) (“FBARs”). We are mindful that the burden estimates for the collection of information often do not reflect the actual burden imposed, but make the...
New FBAR Court Case Makes it Easier for Taxpayers to be Deemed Willful
...inflation) or 50% of the balance in the unreported financial account. A recent court case impacts the FBAR Burden of Proof. What is the FBAR Burden of Proof? When we...
IRS reminds those with foreign assets about U.S. tax obligations
...B asks about the existence of foreign accounts, such as bank and securities accounts, and usually requires U.S. citizens to report the country in which each account is located. In...
Run to the Door: IRS Terminates Offshore Voluntary Disclosure Program (OVDP) effective September 28, 2018
...in 2012, which followed voluntary programs offered in 2011 and 2009. The programs have enabled U.S. taxpayers to voluntarily resolve past non-compliance related to unreported foreign financial assets and failure...
New Unreported Offshore Assets case: Bad facts leads to bad results
...than $10,000, by filing a FBAR, or Foreign Bank Account Report. Enforcement of this law increased after the signing into law of the Foreign Account Tax Compliance Act, or FATCA,...
FBAR statute of limitations court case ruling
...or more assets with respect to which information is required to be reported under section 6038(D). Despite the IRS attempt to draw parallels between Code Section 6038(D) and previously enacted...