The "Report of Foreign Bank and Financial Accounts" (FBAR) penalty has been the subject of much litigation. This Holland & Knight alert focuses on the non-willfulness element of 31 U.S.C. ยง 5321(a)(5)(B). Both the U.S. Court...more
1/10/2022
/ Compliance ,
FBAR ,
Foreign Bank Accounts ,
Income Taxes ,
IRS ,
Penalties ,
Statutory Interpretation ,
Statutory Requirements ,
Tax Audits ,
Voluntary Disclosure ,
Willful Violations
This Holland & Knight alert is not focused on the structured trust advantaged repackaged securities (STARS) transaction or the economic substance doctrine, which were the primary issues before the U.S. Court of Appeals for...more
Virtual currency transactions are now a prime focus of Internal Revenue Service (IRS) scrutiny. The IRS has numerous information-gathering tools to enforce its taxing power, including summons, artificial intelligence, data...more
12/4/2019
/ AICPA ,
Criminal Investigations ,
Cryptocurrency ,
Digital Currency ,
FBAR ,
Financial Transactions ,
FinCEN ,
Internal Revenue Code (IRC) ,
IRS ,
Popular ,
Reporting Requirements ,
Suspicious Activity Reports (SARs) ,
Tax Planning ,
Tax Returns ,
Virtual Currency ,
Voluntary Disclosure