News & Analysis as of

Foreign Bank Account Report Tax Appeals

Rivkin Radler LLP

Unconstitutionally Excessive FBAR Penalties? It Depends

Rivkin Radler LLP on

You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information...more

Foodman CPAs & Advisors

IRS Criminal Investigation Unit (IRS-CI) will find you!

Due to the Foreign Account Tax Compliance Act (FATCA) and the work of IRS special agents, international tax transparency is here. There is virtually nowhere to hide. On 1/18/17, the Department of Justice (DOJ) reported that...more

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