Streamlined Foreign Offshore Procedures
The streamlined foreign offshore procedures (SFOP) are part of the streamlined filing compliance procedures. Unlike the streamlined domestic offshore procedures, there is no 5% misc. offshore …
The streamlined foreign offshore procedures (SFOP) are part of the streamlined filing compliance procedures. Unlike the streamlined domestic offshore procedures, there is no 5% misc. offshore …
Many Taxpayers have filed under the delinquent international information return submission procedures (DSP). Contents1 What are the Delinquent International Information Return Submission Procedures?1.1 Changes after …
Read moreDelinquent International Information Return Submission Procedures
Contents1 Streamlined Domestic Offshore Procedures – Overview2 Eligibility for the streamlined domestic offshore procedures2.1 Non-willfulness3 Disqualification from the streamlined domestic offshore procedures4 Title 26 miscellaneous …
After a district court in Texas recently held that penalties for the non-willful failure to file an FBAR is be assessed by form (and not …
The IRS Small Business & Self-Employed Division updated guidance (SBSE-04-1120-0074) for foreign bank account report compliance activity due to the COVID-19 pandemic. A text of …
Read moreIRS Issues Temporary Guidance for FBAR Compliance Enforecement
In a recent case before the U.S. Court of Federal Claims, two married taxpayers appeared pro se in challenging the assessment of passive foreign investment …
The IRS recently announced an LB&I campaign that targets nonresidents who own U.S. rental properties. Based on past experience, IRS campaigns should be taken seriously. …
We had written about the Bittner case before. The IRS had sought to reduce to judgment about $3M of non-willful FBAR penalties, which had been …
Read moreTexas Court Holds that FBAR Nonwillful Penalty is Per Form, Not Per Account
This week the IRS announced a new Section 965 compliance campaign in it’s LB&I division. While U.S. corporations have owed the vast majority Section 965 …
In United States v. Isac Schwarzbaum, No. 9:18-cv-81147, the U.S. District Court of the Southern District of Florida found the taxpayer liable for nearly $13M …
Read moreCourt Outright Rejects Eight Amendment Applicability to FBAR Fines
In early March 2020, the IRS released Rev. Proc. 2020-17 which provides an exemption from the information reporting requirements under IRC § 6048 – specifically, …
Read moreNew Exemptions & Penalty Relief for Form 3520 and 3520-A
In the recent U.S. v. Ram Agrawal; No. 2:18-cv-00504 the district court rejected the taxpayer’s reasonable cause defense. It granted the government summary judgment in …
Read moreCourt Rejects Reasonable Cause Argument in FBAR Penalty Case
On 11/19, the IRS released a memorandum to issue interim guidance to update the process by which IRS accepts requests for confirmation (verification) that the …
Read moreIRS Updates Procedures for FBAR Verification Requests