IRS Announces Section 965 Compliance Campaign
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 …
Court Outright Rejects Eight Amendment Applicability to FBAR Fines
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 …
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New Exemptions & Penalty Relief for Form 3520 and 3520-A
In early March 2020, the IRS released Rev. Proc. 2020-17 which provides an exemption from the information reporting requirements under IRC § 6048 – specifically, …
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Court Rejects Reasonable Cause Argument in FBAR Penalty Case
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 …
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IRS Updates Procedures for FBAR Verification Requests
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 …
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Incorporating a Business in Texas
Texas is a relatively business-friendly state for incorporating a new business. The formation process itself can be deceptively simple. There’s more than simply filing the …
Government Seeks Judgment for FBAR Penalties Against Oregon Woman
In U.S. v. Tonisson, No. 3:19-cv-01497, the government filed a complaint to reduce to judgment almost $100,000 in FBAR penalties for Taxpayer’s non-willful failure to …
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Government Seeks $2.7 million after Incomplete Offshore Disclosure
If you have undisclosed foreign accounts, perhaps the only thing worse than not coming forward voluntarily is submitting an incomplete disclosure. In United States v. …
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Former CPA Charged with Filing False Streamlined Submission
From the DOJ press release. A federal grand jury returned a superseding indictment charging Brian Booker, a former resident of Fort Lauderdale, Florida, whose business …
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IRS Again Asserts Multiple Non-Willful FBAR Penalties
Just when it seemed that things couldn’t get any stranger in the world of foreign accounts compliance… In United States v. Bittner, No. 19-cv-00415 (ED …
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