FBAR

Did the IRS Assess International Information Return Penalties Against You? You Might Be Entitled to a Refund Based on a Recent Tax Court Opinion

by David J. Warner | Apr 4, 2023 | FBAR, Internal Revenue Service, Offshore Income, U.S. Tax Court

On April 3, 2023, the U.S. Tax Court issued its opinion in Farhy v. Commissioner, 160 T.C. No. 6 (2023). This case deals a major blow to the Internal Revenue Service (IRS) and its efforts to collect penalties related to certain international information returns. Did...

Michele Weiss Analyzes Effects of U.S. Supreme Court’s FBAR Opinion in Bittner v. U.S. for Beverly Hills Bar Association Webinar

by Michele Weiss | Apr 4, 2023 | FBAR, Internal Revenue Service, Offshore Income

Michele Weiss, Principal at Holtz, Slavett & Drabkin, will participate in a Beverly Hills Bar Association panel exploring how to navigate the new landscape for Foreign Bank Account Report (FBAR) penalties in light of the U.S. Supreme Court decision in Bittner v....

Are FBAR Penalties Limited? U.S. Supreme Court Will Decide.

by David J. Warner | Jun 22, 2022 | FBAR, Internal Revenue Service, Offshore Income

On June 21, 2022, the U.S. Supreme Court decided to review (that is, granted certiorari) in the case of Bittner v. United States. This case centers around the report of foreign bank and financial accounts (FBAR) and penalties for not timely filing the FBAR form. The...

Can Non-Willful FBAR Penalties Exceed $10,000 Per Year?

by Michele Weiss | Mar 22, 2022 | FBAR, Internal Revenue Service, Offshore Income

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

by Igor Drabkin | Aug 31, 2020 | Audit, FBAR, Internal Revenue Service, Offshore Income, Tax Litigation, Uncategorized

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

by Gary Slavett | Mar 25, 2020 | Audit, COVID-19, Criminal Tax, Employment Tax, Exempt Organizations, FBAR, Innocent Spouse Relief, Internal Revenue Service, Offshore Income, Tax Collection, Tax Litigation, Trust Fund Recovery Penalty

IRS temporarily adjusts and suspends key compliance programs to help people facing the challenges of COVID-19 issues.