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, …
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 $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. …
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 …
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 …
IRS Begins Sending Letters to Cryptocurrency Owners
The IRS has started sending letters to taxpayers with currency transactions and who potentially failed to report income and pay tax resulting from the virtual …
Is Summary Judgment Appropriate for FBAR Willfulness Finding?
In United States v. Horowitz, an OVDI/OVDP “opt out” case, the Taxpayer appeals a summary judgment decision involving FBAR willfulness penalties. Contents1 Facts2 Was summary …
Court Finds that FBAR Penalties Can Be Assessed After Taxpayer’s Death
Can the IRS assess penalties against a deceased taxpayer for previously failing to file an FBAR? And who can the government collect the penalties from …
Government Seeks to Collect $1.1 Million for Unreported Swiss Accounts
In U.S. v. Kochav, case number 9:19-cv-80648, the Government seeks to reduce a $1.1 million willful FBAR civil penalty assessment to judgment. It’s helpful for …
Court Sustains Non-willful FBAR Penalty on Per Account Basis
Can FBAR penalties be assessed on a per account basis? In the recent United States v. Boyd, the court answered that question when it found …