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16 May 2012, 3:56 pm
So we're still on a parallel track with our main blog (these will separate again after we complete the FBAR amnesty discussion). [read post]
15 May 2012, 3:05 pm
Furthermore, the civil statute of limitations on Report of Foreign Bank and Financial Accounts (FBAR) errors or misreports is 6 years plus all criminal cases carry a 6 year statute of limitations also. [read post]
12 May 2012, 2:24 pm
All of the technical issues are discussed in IRS Notice 2009-85. [read post]
6 May 2012, 9:35 am
The taxpayer in these circumstance may also have to file a Report of Foreign Bank Account (FBAR). [read post]
25 Apr 2012, 10:23 am
The current IRS international FBAR enforcement program is soon to present a major challenge to the leadership of the IRS. [read post]
22 Apr 2012, 4:59 pm
As the Department of Justice press release notes: Rick Matsa individually was convicted of one count of a corrupt endeavor to obstruct and impede the IRS, 15 counts of aiding and assisting in the preparation of false and fraudulent tax returns, that related to five different trusts; one count of willfully failing to file a Report of Foreign Bank and Financial Accounts (FBAR); one count of conspiracy to obstruct justice, commit perjury, and make false statements; two counts of… [read post]
18 Apr 2012, 11:39 am
This form essentially requires American taxpayers to disclose all of their foreign assets over a threshold amount in addition to disclosing foreign bank accounts to the IRS on FBAR forms. [read post]
14 Apr 2012, 11:52 am
" Subsequent to the Moore case, the IRS issued Rev. [read post]
10 Apr 2012, 5:23 pm
This form is filed in addition to the FBAR and is duplicative of a lot of the information reported on the FBAR. [read post]
9 Apr 2012, 6:06 pm
All tax practitioner’s must be careful to advise clients about the client’s disclosure obligations and take special notice of IRS Circular 230 rules of practice. [read post]
7 Apr 2012, 5:32 pm
As the IRS focuses more and more resources on international tax evasion techniques and tax evasion careful reporting is a must to avoid penalties, including penalties for tax evasion, tax fraud and FBAR penalties. [read post]
4 Apr 2012, 2:32 pm
" Subsequent to the Moore case, the IRS issued Rev. [read post]
4 Apr 2012, 6:23 am
Therefore, it’s important to note that while you file FBAR with the Department of Treasury and it is enforced by the IRS, your filing of FBAR alone will not result in taxes owed. [read post]
31 Mar 2012, 10:29 am
New IRS Form 8938 give the IRS greater information and enforcement powers. [read post]
23 Mar 2012, 7:00 am
As a technical matter it is not clear to our tax litigation lawyers that the IRS has the right to seize the proceeds of an account simply because no FBAR was filed. [read post]
18 Mar 2012, 10:48 am
Second, he should have filed an FBAR for each year each of the offshore accounts was open and had $10,000 or more. [read post]
18 Mar 2012, 2:56 am
A person who became a "cooperating witness" helped him open the account and told him about the FBAR requirement, but Brandner didn't file the required report. [read post]
16 Mar 2012, 10:03 am
Your starting point should be form 8938 which covers all foreign assets including everything which would be included on this June's FBARs. [read post]
14 Mar 2012, 4:28 pm
If all my savings is in gold bars, do I have to worry about FBARs or form 8938? [read post]
13 Mar 2012, 8:45 am
Most foreign banks will ultimately report U.S. depositor account information to IRS. [read post]
