Tax Lawyer Blog

Other Posts in this Series Part I Part III In Part I, we listed some of the penalties associated with the failure to report foreign accounts, and what is widely regarded as the best option for coming into compliance – the Offshore Voluntary Disclosure Program (OVDP). In this post, we...

Other Posts in this Series Background of Administrative Procedure Act Rulemaking Requirements Under the APA Adjudication and Licensing Judicial Review Over the past 10 years, thousands of U.S. taxpayers with a wide variety of circumstances have been forced to pay extraordinarily high penalties for failure to disclose foreign bank accounts....

Both Prior Submissions and Future Submissions Effected (Announced by Government June 21, 2016) Treasury Inspector General's Report Issued to Internal Revenue Service Criminal Division and International Division In a report issued to the Internal Revenue Service International Division and Criminal Division, the Treasury Inspector General for Tax Administration (TIGTA) found...

The U.S. crackdown on offshore tax havens is making the act of hiding money overseas a thing of the past. Foreign financial institutions are now required to report information regarding their U.S. account holders. Tens of thousands of U.S. taxpayers have paid massive penalties for undeclared foreign accounts and many...

This is a continuation of Part I on this topic. The IRS has wide discretion when it comes to the imposition of FBAR penalties. In our last post, we reviewed the basic FBAR rules and penalties, and noted how IRS examiners have the discretion to waive the penalty. In this...

In an attempt to fight money laundering in the U.S., Congress passed the Bank Secrecy Act in 1970. Among the Act's requirements was the filing of FinCEN Form 114 (formerly Treasury Department Form 90-22.1) Report of Foreign Bank and Financial Accounts (FBAR). For many decades, compliance was low. This changed...