News & Analysis as of

Foreign Bank Account Report Penalties Offshore Funds

Allen Barron, Inc.

How Does the IRS Define Willfulness in Unreported or Under-reported Offshore Income

Allen Barron, Inc. on

How does the IRS define willfulness in unreported or under-reported offshore income?  What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct?  Why should U.S. taxpayers be...more

Allen Barron, Inc.

Questions Regarding Offshore Accounts and FBAR Filing Requirements

Allen Barron, Inc. on

Many US taxpayers still have questions regarding offshore accounts and FBAR filing requirements and compliance. Is there a genuine risk their activities (or lack of compliance) will come to light? The definition of a US...more

Allen Barron, Inc.

The Risks of an IRS Quiet Disclosure

Allen Barron, Inc. on

What are the risks of an IRS quiet disclosure? Is there a formal IRS process known as a "quiet disclosure," and does the IRS honor this strategy for amended tax returns?...more

Allen Barron, Inc.

Are There Strategies to Avoid an IRS Audit?

Allen Barron, Inc. on

Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to...more

Gray Reed

FBAR Penalty Defenses and Techniques: The Wrong “Willful” Penalty Computation

Gray Reed on

On September 8, 2023, the IRS issued a News Release suggesting that FBAR compliance investigations and audits would heat up in the near future.  For those unfamiliar with FBARs, federal law requires United States persons to...more

BakerHostetler

Per-Account or Per-Form Penalty?

BakerHostetler on

Key Takeaways: ..The law regarding computation of FBAR penalties is unclear. ..The United States Supreme Court has agreed to hear a case to settle a conflict among the circuit courts. ..Until the Supreme Court...more

Freeman Law

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

Freeman Law on

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

Rosenberg Martin Greenberg LLP

Ruling Provides for Significant Limitation on Amount of Penalties

On May 15, 2018, the United States District Court for the Western District of Texas issued an important ruling concerning the application of willful FBAR penalties under 31 U.S.C. § 5321. In United States v. Colliot, Case...more

Mitchell, Williams, Selig, Gates & Woodyard,...

DOJ Announces Major New Shift in Criminal Sentencing in Offshore Tax Matters

At the 34th Annual National Institute on Criminal Tax Fraud in Las Vegas yesterday afternoon, Mark Daly, DOJ Tax Division Senior Litigation Counsel announced a major new shift in how the Department of Justice plans to argue...more

Perkins Coie

Will the Panama Papers Lead to Criminal Charges Against U.S. Taxpayers?

Perkins Coie on

The International Consortium of Investigative Journalists (ICIJ), collaborating with German newspaper Süddeutsche Zeitung, in spring 2016 began leaking approximately 11 million internal documents obtained without permission...more

Patterson Belknap Webb & Tyler LLP

IRS Announces Changes to the Offshore Voluntary Disclosure Program

As you may have read, the Internal Revenue Service (“IRS”) recently announced changes to its offshore voluntary disclosure programs and announced new options for taxpayers to come into compliance with their U.S. tax...more

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