Bank Secrecy Act, Tax Returns

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The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide documentation to authorities for single transactions of more than $10,000 and report other suspicious account activity that could signify money laundering or other financial crimes. less -

Taxpayers Abroad are Underserved and Challenged

Foodman CPAs & Advisors on 9/6/2024

The National Taxpayer Advocate 2023 Annual Report to Congress highlights how Taxpayers abroad are underserved and continue to face challenges in meeting their U.S. tax obligations. As a result, the National Taxpayer Advocate...more

Tenth Circuit Affirms Deficiencies, Penalties for Offshore Income

Lerch, Early & Brewer on 4/4/2023

Harrington v. Commissioner - In Harrington v. Commissioner of Internal Revenue, George S. Harrington (Harrington) challenged tax deficiencies and fraud penalties assessed for tax years 2005 through 2010. Originally...more

Supreme Court Hands Taxpayers a Victory in FBAR Penalty Case

Cadwalader, Wickersham & Taft LLP on 3/22/2023

Taxpayers recently won a significant victory at the Supreme Court in a penalty case involving a non-willful failure to file a Report of Foreign Bank and Financial Accounts (“FBAR”) under the Bank Secrecy Act (the “BSA”)....more

A Current “Playoff Picture” of Non-Willful FBAR Violations

Freeman Law on 1/21/2022

It’s that time of year again. Various football teams scramble at the end of the regular season for a chance at the playoffs. And with each game’s conclusion spectators get an updated “playoff picture” with respect to where...more

Do FBAR Penalties Survive Death? A Texas Court Says “Yes”

Freeman Law on 8/10/2021

A federal district court in Texas recently took up an interesting FBAR issue: whether civil FBAR penalties survive death? That is, if a taxpayer/account holder dies after the IRS assesses an FBAR penalty against them, do the...more

Federal Court Imposes Willful FBAR Penalties on Long-Time CPA

Freeman Law on 7/21/2021

In a recent decision, a federal district court found that a long-time CPA/tax-return preparer recklessly failed to file FBARs to disclose several foreign financial accounts. As avid readers of our Insights are aware, many...more

What You Need to Know about the Corporate Transparency Act

Foley & Lardner LLP on 1/12/2021

On January 1, 2021, Congress passed the National Defense Authorization Act for Fiscal Year 2021, which includes the Corporate Transparency Act (the CTA).1 The CTA requires all U.S. businesses to file “beneficial ownership”...more

Are you a Taxpayer identified by IRS for not Reporting Offshore Financial Assets?

Foodman CPAs & Advisors on 8/7/2017

Taxpayers with unreported foreign financial assets and income run the risk of having the Government determine if their conduct was willful or non-willful. The definition of “Willful" or "non-willful” in Taxpayer’s conduct...more

Failure to Report Foreign Accounts is Illegal, IRS Warns

Ballard Spahr LLP on 4/7/2016

Maintaining a foreign bank or other financial account is not illegal. Such accounts are increasingly common, as the globe shrinks. However, in the case of U.S. citizens or residents (and certain non-residents), failing to...more

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Bank Secrecy Act › Tax Returns

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