US citizens living abroad with foreign assets and bank accounts are required to file an FBAR form with the IRS. Americans earning income in the USA have to file taxes on or before April 15th, but what ...
As previously blogged by Chuck Rettig (2/9.11), Kathy Keneally (12/12/10) and Bob McKenzie (10/01/10), the IRS has been aggressively pursuing the disclosure of foreign financial information by U.S.
WALLINGFORD, CT / ACCESSWIRE / July 27, 2016 / IRSMedic.com, also known as Parent & Parent, LLP, recently announced that its 2015 FBAR filing guide was successfully shared across social media and ...
In a recent case, the Fifth Circuit analyzed whether the $10,000 maximum non-willful FBAR penalty cap applies for each failure to file an annual FBAR or each failure to report an account. In an ...
The penalty for nonwillful failure to file a Financial Crimes Enforcement Network (FinCEN) Form 114, Report of Foreign Bank and Financial Accounts (FBAR), is assessed per FBAR not timely or properly ...
Today, the Supreme Court issued a 5-4 decision in Bittner v. United States, ruling that the Bank Secrecy Act’s $10,000 maximum penalty for a nonwillful failure to file a timely and accurate FBAR ...
The "Report of Foreign Bank and Financial Accounts" (FBAR) penalty has been the subject of much litigation. This Holland & Knight alert focuses on the non-willfulness element of 31 U.S.C. § 5321(a)(5) ...
A district court held that FBAR penalties accrue on the date the FBAR form is due and that an individual’s death did not extinguish these penalties or make them excessive under the Eighth Amendment to ...
Cross-border clients who aren’t caught up on their foreign-account tax filings in the U.S. can breathe a small sigh of relief, but should aim to comply as soon as possible. The U.S. Supreme Court ...
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