FBAR and IRS Reporting Penalty Defense & Litigation
Whether you have failed to report your foreign financial accounts due to a misunderstanding of FBAR or other foreign account reporting requirements, or have deliberately concealed overseas accounts and assets, you need to consult with one of our tax attorneys immediately.
The tax law firm of Moskowitz, LLP has substantial experience with FBAR and IRS reporting penalty defense and litigation that few law firms can match. We have succeeded in defending hundreds of individuals accused of reporting noncompliance, and ours is the only law firm in the U.S. to successfully sue the IRS for the way it assesses FBAR penalties. As a result of our efforts, the IRS was forced to change the Internal Revenue Manual and issue new guidance on FBAR penalties, significantly changing the way the government looks at these cases.
Failing to file an FBAR carries a civil penalty of $10,000 for each non-willful violation. For willful violations, the penalty is the greater of $100,000 or 50% of the account balance. Criminal penalties for FBAR non-compliance include fines of up to $500,000 and up to 10 years in prison.
FBAR penalties are generally accompanied by other civil tax penalties (accuracy-related, tax fraud) and criminal charges (tax evasion, conspiracy). There is no statute of limitations barring the collection of an FBAR penalty, which cannot be discharged in bankruptcy.
Aggressive FBAR defense
If you are currently being investigated by the IRS on a matter involving foreign financial reporting and international tax compliance, or have reason to believe you will be in the future, you need a tax law firm with a history in international tax law and successful record of minimizing FBAR penalties before assessment. We can zealously defend you in a settlement with the IRS or in court.