Are FBAR Penalties Limited? U.S. Supreme Court Will Decide.
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...
Failing to Notify the Franchise Tax Board of an IRS Audit Means the Tax May Not Be Dischargeable in Bankruptcy
No one wants to be audited by the Internal Revenue Service (IRS). However, if the IRS examines your tax return and makes any changes to it, then California taxpayers have an extra obligation to notify the California Franchise Tax Board (FTB) of these changes. Under...
Michele Weiss to Present “IRS & Pass-Throughs: New International Reporting Rules and Enforcement” to the CLA, Tax Section, Women in Tax Committee
On May 17, 2022, Michele Weiss, Senior Counsel at Holtz, Slavett & Drabkin, will present a CLE program on IRS and Pass-Throughs – New International Reporting Rules and Enforcement to the Women in Tax Committee of the California Lawyers Association, Tax Section....
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...
Tax Issues in the Cannabis Industry
The IRS has made tax enforcement in the cannabis industry one of its top priorities.