Tax Practitioner Alert: The IRS Is Assessing Excessive Foreign Bank Account Report (FBAR) Penalties
Certain individuals and entities are required to file a FinCEN Form 114, Report of Foreign Bank Account Report (commonly called an “FBAR”), if they have a financial interest or signature authority in a foreign bank account. The FBAR form is filed electronically on the...
Tax Professionals Be Aware: The Rules for Claiming a Refund of Foreign Bank Account Report (FBAR) Penalties May Have Just Changed
Certain individuals and entities are required to file a FinCEN Form 114, Report of Foreign Bank Account Report (commonly called an “FBAR”), if they have a financial interest or signature authority in a foreign bank account. The FBAR form is filed electronically on the...
Taxpayers Can Still Make Voluntary Disclosures for Offshore Accounts
On November 20, 2018, the IRS issued a Memorandum, describing the process for all voluntary disclosures following the closing of the 2014 OVDP on September 28, 2018. The new procedures are effective for all disclosures after September 28, 2018. Under the new procedures, the taxpayers with hidden foreign bank accounts, whose behavior may be considered willful, will find stricter requirements and higher penalties.
Think the Criminal Statute of Limitations for Failure to Report Foreign Bank Accounts Has Expired? Think Again.
In general, the United States has five years to start criminal proceedings in a criminal case (either through an indictment or information). 18 U.S.C. § 3282. However, there are several statutes that could suspend or extend this five-year period, and an individual might not even know if the statute of limitations has been extended.
Tax Crime Does Not Pay — Says Department of Justice
Tax Crime Does Not Pay — Says Department of Justice