News & Analysis as of

Internal Revenue Code (IRC) Foreign Bank Account Report FinCEN

Freeman Law

Willful FBAR Penalties and the Excessive Fines Clause: District Court Says Context is Key

Freeman Law on

In its recent decision in United States v. Leeds, the United States District Court for the District of Idaho upheld the application of willful penalties against a deceased husband for failing to report certain foreign bank...more

Allen Barron, Inc.

A Foreign Trust Creates Complex IRS Reporting Requirements

Allen Barron, Inc. on

The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more

Davies Ward Phillips & Vineberg LLP

Federal Courts Weigh in on the FBAR: Providing Relief from Outrageous Penalties

In this bulletin, we highlight two recent federal court cases in which U.S. taxpayers won major victories against the United States with respect to their obligations to report non-U.S. accounts on FinCEN Form 114 – Report of...more

McDermott Will & Emery

Weekly IRS Roundup December 23 – 27, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more

Holland & Knight LLP

Virtual Currency: The Taxman is Coming

Holland & Knight LLP on

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

Foodman CPAs & Advisors

De-Risking 101

Foodman CPAs & Advisors on

Bank Secrecy Act of 1970 - Requires U.S. financial institutions to assist U.S. government agencies to detect and prevent money laundering by keeping records of cash purchases of negotiable instruments, and file reports...more

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