More than 25 years ago, Congress enacted Internal Revenue Code Section 6751(b) to protect taxpayers from the IRS using penalties as a bargaining chip in an effort to coerce taxpayers to settle. Generally, Section 6751(b)...more
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