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22 Nov 2017, 8:27 am by Dennis N. Brager
If you submit your amended returns under the Streamlined Procedures, but the IRS later decides that you were a willful FBAR violator, you could subject yourself to these penalties, along with the potential threat of criminal prosecution. [read post]
6 Nov 2017, 8:07 am by Dennis N. Brager
If you aware that you have unreported foreign financial accounts that expose you to liability for Foreign Bank Account Report (FBAR) or Foreign Account Tax Compliance Act (FATCA) violations, you should carefully consider the risks of waiting to disclose your offshore accounts, including the following: The IRS does not have to continue to offer offshore disclosure programs, and can change the terms of these programs whenever they wish. [read post]
25 Sep 2017, 6:09 am by Matthew D. Lee
In 2013, the IRS concluded that Bedrosian’s failure to report one of two foreign bank accounts on a 2007 FBAR was willful. [read post]
15 Sep 2017, 8:46 am by Dennis N. Brager
The IRS has six years from the due date of the FBAR to assess the FBAR penalty. [read post]
14 Sep 2017, 8:43 am by Dennis N. Brager
The IRS imposes severe penalties on taxpayers who fail to file a Report of Foreign Bank and Financial Accounts (FBAR). [read post]
15 Aug 2017, 6:59 am by Kelly Phillips Erb
I never allow my bank account to have a balance greater than $10K so as not to have to submit a FBAR. [read post]
1 Aug 2017, 8:34 am by Dennis N. Brager
While this may prevent any future offshore bank account problems, it does not stop the IRS from discovering any past delinquent FBARs and assessing severe civil and/or criminal penalties. [read post]
30 Jul 2017, 4:38 am by Matthew D. Lee
In addition to filing false tax returns and FBARs, Khoubian is alleged to have provided his German bank with a copy of his Iranian passport and a residential address located in Israel to prevent the bank from disclosing the account to the IRS. [read post]
6 Jul 2017, 8:51 am by Dennis N. Brager
Other violations may be less excusable, or—as the IRS designates them— “willful”. [read post]
14 Jun 2017, 7:54 am by Charles (Chuck) Rubin
In the past, the FBAR deadline was June 30 and no extensions were available. [read post]
5 Jun 2017, 1:29 pm by Matthew D. Lee
While offshore tax compliance has been a top DOJ and IRS priority since 2009, the criminal cases that have been filed as part of that initiative have focused for the most part on the tax and FBAR reporting obligations associated with individuals who maintain foreign bank accounts. [read post]
19 May 2017, 8:48 am by Dennis N. Brager
Internal Revenue Manual (IRM) 4.26.16.6 states that when an FBAR violation is found, the IRS examiner must either issue a Letter 3800 or issue a penalty. [read post]
27 Apr 2017, 8:16 am by Dennis N. Brager
The IRS streamlined filing compliance procedures and the Offshore Voluntary Disclosure Program (OVDP) are two different methods that can be used to resolve your offshore bank account problems. [read post]
25 Apr 2017, 2:34 pm by Daniel Shaviro
"The paper uses IRS data to examine what happened after (and presumably in consequence of) a number of steps being taken to address U.S. individual income tax evasion via the hiding of income in foreign accounts. [read post]
18 Apr 2017, 8:47 am by Dennis N. Brager
The IRS Offshore Voluntary Disclosure Program (OVDP) offers taxpayers with unreported income from foreign financial accounts a chance to come into compliance with the law. [read post]
16 Apr 2017, 12:58 pm by Michael Froomkin
US personal tax returns are normally due on April 15; because the 15th fell on a Saturday this year, the IRS extended the date to April 18. [read post]
13 Apr 2017, 8:43 am by Dennis N. Brager
The IRS expanded its streamlined filing compliance procedures in 2014 to allow more taxpayers with offshore bank accounts to take advantage of the program. [read post]
11 Apr 2017, 8:40 am by Dennis N. Brager
FBAR Filing Requirements for Non-Citizens The IRS has its own rules for determining if you are a resident for tax purposes. [read post]
30 Mar 2017, 9:00 pm
   The annual filing date for FBARs is April 15, and the maximum extension of the filing deadline is six-months, according to the IRS. [read post]