Can Non-Willful FBAR Penalties Exceed $10,000 Per Year?
by Michele Weiss US taxpayers are obligated to file a foreign bank account report (“FBAR”) if the aggregate value of their foreign account interests exceeds $10,000 on any day during a calendar year. 31 U.S.C. § 5314; 31 C.F.R. §§ 1010.350(a), 1010.306(c). Taxpayers...
Recent FBAR Cases Show Mixed Results in Taxpayers Fighting Against Aggressive Penalties
Crackdown on the offshore accounts continues to be one of the top priority issues for the IRS. In the last few years, the DOJ and the IRS have taken aggressive positions in imposing and collecting huge penalties for taxpayers’ failure to report their foreign accounts...
IRS implements new COVID-19 Initiative to Assist Taxpayers
IRS temporarily adjusts and suspends key compliance programs to help people facing the challenges of COVID-19 issues.
Renouncing US Citizenship and US Tax Obligations
Giving up your U.S. citizenship is considered a taxable event, i.e. the IRS treats the date of the renunciation (or technically, the date before the renunciation) of the citizenship as a date of the virtual sale of the assets at a market price.
Israeli Bank Mizrahi-Tefahot Admits to Helping US Taxpayers Conceal Income and Assets; Agrees to Pay $195 Million to U.S.
Israeli Bank Mizrahi-Tefahot Admits to Helping US Taxpayers Conceal Income and Assets; Agrees to Pay $195 Million to U.S.