Tag Archives: FBAR

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) of the Department of the Treasury can levy high penalties

Reasonable Cause Defense Denied: FBAR Penalties Assessed by Court

  In the recent 2019 case U.S. v. Ram Agrawal, a US District Court rejected a taxpayer’s reasonable cause defense against foreign bank account reports (FBARs) penalties. It ruled in favor of the government to collect FBAR penalties for the

IRS Updated Voluntary Disclosure Practice is a Game-Changer

Last week the IRS released a memorandum with new procedures for  an “Updated Voluntary Disclosure Practice” impacting all voluntary disclosures. The new updated voluntary disclosure practice (VDP) is a game-changer for offshore voluntary disclosures for US persons with unreported foreign assets. The

ABA Conference with Government Officials

The ABA recently held a conference titled National Institute on Criminal Tax Fraud and Institute on Tax Controversy.  I attended the conference where many tax attorneys and government officials discussed issues of interest. Also discussed was the effect of streamlined