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 …
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 …
Delinquent International Information Return Submission Procedures
Delinquent international information return submission procedures (DSP) were one of the four methods for taxpayers with unreported offshore accounts to become compliant. Contents1 What are …
Ninth Circuit Holds that Non-Willful FBAR penalty is Assessed Per Form
Following a string of other similar decisions, the Ninth Court Court of Appeals in United States v. Boyd finds that the non-willful FBAR penalty is …
Virginia Man is Charged with Filing False Streamlined Filing
In at least the second such instance that we’re aware of, the Government has brought charges related to filing a false streamlined submission, among other …
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 …
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
In United States v. Bittner, the IRS had sought to reduce to judgment about $3M of non-willful FBAR penalties, which had been assessed per account. …
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 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 …
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, …