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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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 …
Read moreGovernment Seeks Judgment for FBAR Penalties Against Oregon Woman