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15 Nov 2012, 8:11 am
” “This case, like Williams, appears to eschew the strict criminal standard of willfulness that the IRS has for years applied to the civil FBAR penalty,” said Jim Mastracchio, Co-Chair of the firm’s Tax Controversy Practice. [read post]
29 Jun 2009, 12:42 pm
Joe Kristan of Roth & Company’s TaxUpdates blog informs readers about IRS relief for new filers of FBAR Form TD 90-22.1: The IRS says that folks who didn’t know about their foreign financial account (”FBAR”) reporting requirements until recently, but who have reported whatever foreign income they have earned for 2008, may file their current report on Form 90-22.1 as… [read post]
16 Oct 2013, 1:00 am
Rettig (Hochman, Salkin, Rettig, Toscher & Perez, Beverly Hills, CA) has posted several of his tax papers on SSRN: The 2012 IRS Offshore Voluntary Disclosure Initiative Form 8300: Reporting Domestic Currency Transactions GAO to IRS: 'Pursue Quiet Disclosures and First Time FBAR Filers' Innocent Spouse: Separating the Marital... [read post]
13 Feb 2022, 9:00 pm
If you need to file, should you file IRS Form 8938, an FBAR or both? [read post]
2 Oct 2009, 4:01 am
" As a result, the will not be able to reduce their exposure to penalties for having failed to file an FBAR form. [read post]
30 May 2014, 3:14 pm
n a jury verdict this wake in the Southern District of Florida, the IRS has a sharpened Sword of Damacles to hang over the head of FBAR reporting violators. [read post]
29 Sep 2016, 9:00 am
Our most recent survey targeted tax preparers and their interaction with the IRS in a number of areas, including disclosure programs, FBARs and marijuana businesses. [read post]
29 Sep 2016, 9:00 am
Our most recent survey targeted tax preparers and their interaction with the IRS in a number of areas, including disclosure programs, FBARs and marijuana businesses. [read post]
29 Sep 2016, 9:00 am
Our most recent survey targeted tax preparers and their interaction with the IRS in a number of areas, including disclosure programs, FBARs and marijuana businesses. [read post]
27 Jun 2012, 9:39 am
The IRS announced yesterday a new procedure to deal with “low compliance risk” taxpayers who have innocently not filed FBARs or tax returns noting their RRSPs (a Canadian retirement account similar to a 401(k) or IRA). [read post]
10 Dec 2013, 6:33 am
Pursuant to this federal law, the IRS requires that Form 8938 (Statement of Specified Foreign Financial Assets) be filed annually to report interests by U.S. persons in foreign accounts. [read post]
26 Jun 2012, 3:16 pm
The new FAQs are available here: new%20FAQs.pdf The IRS also announced that it will provide special procedures for US citizens living abroad who failed to file US income tax returns and FBARs but have little to no U.S. tax liability. [read post]
21 May 2009, 5:04 am
The granting, by IRS, of an extension to file Federal income tax returns does not extend the due date for filing an FBAR. [read post]
6 Mar 2015, 1:00 pm
Furthermore, some taxpayers may also be required to file IRS Form 8938 to report the same assets reported on the FBAR. [read post]
24 Dec 2018, 10:10 am
§5314] when he either knowingly or recklessly fails to file [a]FBAR. [read post]
8 Jan 2021, 7:11 am
Reporting Virtual Currency on FBARs On December 31, 2020, the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) in a notice stated it intends to propose to amend the regulations implementing the Bank Secrecy Act (BSA) regarding reports of foreign financial accounts (FBAR) on IRS FinCEN Form 114 to include virtual currency as a type of reportable account under 31 C.F.R. [read post]
8 Jan 2021, 7:11 am
Reporting Virtual Currency on FBARs On December 31, 2020, the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) in a notice stated it intends to propose to amend the regulations implementing the Bank Secrecy Act (BSA) regarding reports of foreign financial accounts (FBAR) on IRS FinCEN Form 114 to include virtual currency as a type of reportable account under 31 C.F.R. [read post]
15 Mar 2016, 9:42 am
FBAR civil penalties are a penalty commonly imposed by the IRS on individuals with illegal offshore accounts. [read post]
13 Oct 2010, 8:11 pm
The FBAR rules are draconian, and the IRS (and Department of the Treasury) have been imposing penalties is a very draconian nature. [read post]
16 Oct 2011, 10:43 am
One of the key questions in the IRS Offshore Voluntary Disclosure letter is “source of funds”. [read post]
