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 …
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 …
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 …
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 …
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 …
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 …
Each year the IRS rolls out campaigns to identify the the top compliance issues for the year. For each of these campaigns, the IRS will …
Few things are more confusing for U.K. foreign nationals and U.S. expats residing in the U.K. than the U.S. tax code, especially as it applies …
Recently, a California U.S. District Court entered default judgment in favor of the Government in an FBAR penalty suit in the case of United States …
We write this article because we frequently have clients come to us after having read another blog or after their own casual reading of an …
According to the IRS, foreign trusts are a major compliance issue: Citizens and residents of the United States are taxed on their worldwide income. To …