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 …
Delinquent International Information Return Submission Procedures
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 …
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Streamlined Domestic Offshore 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 …
District Court Says Only One FBAR Penalty Per Form
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 …
IRS Issues Temporary Guidance for FBAR Compliance Enforecement
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 …
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Taxpayers challenge IRS’s Assessment of PFIC Taxes
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 …
New IRS Campaign Targets Nonresident Rental Income
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. …
Texas Court Holds that FBAR Nonwillful Penalty is Per Form, Not Per Account
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 …
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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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