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

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?

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

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

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.

Renouncing US Citizenship and US Tax Obligations

Renouncing US Citizenship and US Tax Obligations

by Igor Drabkin | Mar 6, 2020 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income

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.

by Igor Drabkin | Mar 15, 2019 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income

Israeli Bank Mizrahi-Tefahot Admits to Helping US Taxpayers Conceal Income and Assets; Agrees to Pay $195 Million to U.S.

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Holtz, Slavett & Drabkin
Former IRS Tax Attorneys
(310) 550-6200
10940 Wilshire Boulevard
Suite 2000
Los Angeles, CA 90024

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  • Holtz, Slavett & Drabkin Attorneys Named 2023 Super Lawyers in Tax Law
  • Holtz, Slavett & Drabkin Attorneys Named 2023 Super Lawyers in Tax Law
  • Holtz, Slavett & Drabkin Sponsors the American Bar Association Tax Section 2023 Midyear Meeting
  • David J. Warner and Igor S. Drabkin Analyze IRS Eggshell Audits with Potential Criminal Issues in Strafford Webinar
  • Holtz, Slavett & Drabkin Moves Its Main Office to Los Angeles (Westwood)
Internal Revenue Service > FBAR

Los Angeles Main Office

10940 Wilshire Boulevard
Suite 2000
Los Angeles, CA 90024
Phone: (310) 550-6200
Fax: (310) 774-3904

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4695 MacArthur Court
Suite 200
Newport Beach, CA 92660
Phone: (949) 999-6606
Fax: (949) 544-0440

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  • Holtz, Slavett & Drabkin Attorneys Named 2023 Super Lawyers in Tax Law
  • Holtz, Slavett & Drabkin Attorneys Named 2023 Super Lawyers in Tax Law
  • Holtz, Slavett & Drabkin Sponsors the American Bar Association Tax Section 2023 Midyear Meeting
  • David J. Warner and Igor S. Drabkin Analyze IRS Eggshell Audits with Potential Criminal Issues in Strafford Webinar
  • Holtz, Slavett & Drabkin Moves Its Main Office to Los Angeles (Westwood)
  • Holtz, Slavett & Drabkin Sponsors the American Bar Association 39th Annual National Institute on Criminal Tax Fraud and the 12th Annual National Institute on Tax Controversy
  • IRS Audits of Employee Retention Credits Are Beginning. Are Taxpayers Ready?

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