foreign bank account
FBAR Not Limited to $100,000, Willfulness Upheld
There have been a number of recent court cases involving foreign bank account or FBAR reporting penalties. This is likely due to the significant amount of the penalty and that many do not fully appreciate the amount of the liability they face if caugh…
Court: IRS Cannot Apply New Law Based on Conduct Predating the Law
In Rafizadeah v. Commissioner, 150 T.C. No. 1 (2018), the court concluded that the IRS made a late assessment of tax and penalties. The case turns on whether the IRS can benefit from the longer six-year assessment period based on …..
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The Benefits of IRS’s Streamlined Procedures for Reporting Foreign Accounts
Given its limited resources and ability to detect foreign assets, accounts and income, the IRS has offered various voluntary programs to entice taxpayers to come clean and report this information. The IRS’s OVDP program and the more recent streamlined procedures are two examples. The Maze v. Internal Revenue Service, Nos. 15-1806 (D.D.C. 2016), highlights several[…]
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