Implications of United States v. Horowitz: Reckless = Willful?
...they will also be considered willful when they recklessly fail to report foreign accounts. Taxpayers who have foreign accounts or have been sent a violation for failure to file an...
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The IRS’ Complex Statute of Limitations
...of the statute of limitations can terminate an audit. When the IRS begins auditing a taxpayer, the statute of limitations begins either when the tax return was due, April 15,...
Willful FBAR Penalties
...end of the day on June 30th of the year after the calendar year for which the accounts are being reported. The FBAR is not filed with your federal tax...
Expect new aggressive IRS targeted enforcement next year.
...loss of tax revenue. It appears that is about to change. President Biden is about to announce a major new increase in IRS tax enforcement funding to tackle the tax...
The Dreaded IRS Letter 6185: “We received information that you have a foreign account”
...foreign financial accounts, foreign entities, or foreign financial assets.” This letter is an IRS “soft letter” (i.e., a warning letter) to U.S. taxpayers owning foreign accounts. These soft letters indicate...
New Favorable Court Decision: One penalty (not multiple) applies for late FBAR filing
...13 FBAR violations—one violation for each account she failed to timely report for calendar year 2010 (the 14th account funded several of the other accounts). The late-submitted FBAR was found...
Rare confluence of tax law and immigration law
...Reports of Foreign Bank and Financial Accounts (FBARs) and naturalization fraud. According to the indictment, Gatta was born in Chile and became a naturalized U.S. Citizen in 2012. The indictment...
“Financial interest” or “Signature Authority” in a Foreign Account
...point during the year, must file a Foreign Bank Account Report (FBAR). However, “financial interest” in or “signature authority” are often confusing and misunderstood. “Signature Authority” in a Foreign Account...
Tax Strategies to Explore Now
...be a viable alternative to lower the overall tax burden faced. In changing domicile care must be cautiously taken as each state has its own intent driven indicators such as...
The FinCEN Files Leak
The FinCEN Files are leaked documents from the US Financial Crimes Enforcement Network (FinCEN), that have been globally earlier published this week. FinCEN is an agency US Treasury that collects...
Caution: Increased FBAR Enforcement
The last month or so has unfortunately seen a lot of FBAR enforcement court rulings against US taxpayers and in favor of the government. The Financial Crimes Enforcement Network (FinCEN)...
FBARs from Wuhan
...Principal Investigator of the Lieber Research Group at Harvard University, which received more than $15 million in federal research grants between 2008 and 2019. Unknown to his employer, Harvard University,...