FBAR and IRS Reporting Penalty Defense and Litigation

In Depth


FBAR Penalty Defense and Litigation

Our tax law firm has been successful in defending against willful FBAR penalties and non-willful FBAR penalties. Further, there have been few court cases brought contesting FBAR penalties, and the procedures and meaning of the statutes imposing the penalties related to failing to file foreign bank account report forms (FBAR). We zealously and aggressively defend our clients. In fact, we are the only law firm in the United States that has taken the fight to the IRS. We have sued the federal government under the Administrative Procedure Act in Federal District Court on the grounds that the IRS acted arbitrarily or capriciously, and abused its discretion in the matter it assessed FBAR penalties. As a result, the IRS changed the way it determines, calculates, and assess FBAR penalties.

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