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
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 …
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
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. …
Read moreGovernment Seeks $2.7 million after Incomplete Offshore Disclosure
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 …
Read moreFormer CPA Charged with Filing False Streamlined Submission