Is your investment in a cryptocurrency such as bitcoin triggering IRS FBAR reporting requirements for your tax return? What are the potential penalties for failing to disclose your bitcoin holdings, especially if they are housed in an offshore exchange? if you have amassed more than $10,000 in your digital wallet or...
New Case May Offer Some Protection from IRS Collection of FBAR Penalties
A recent court decision may provide taxpayers relief and protection from IRS collection of FBAR penalties based upon a 3 year statute of limitations. The US Tax Court has issued its first decision of 2018 which considered whether FBAR related collections by the IRS could go back six years. The...
Ignorance of IRS FBAR Reporting is Not a Defense
Our offices have handled many cases recently of foreign nationals and spouses with offshore accounts and assets who were not aware of their IRS FBAR reporting requirements. Unfortunately ignorance of IRS FBAR reporting is not a defense and the IRS is ruthlessly pursuing huge penalties and interest for those who...
IRS and Bitcoin – Do Crypto Currencies Need to be Reported on the FBAR
The IRS believes that virtual currencies such have Bitcoin have become a tool in tax evasion, and the agency is signalling more enforcement actions and IRS audits in the coming months. The real question many crypto currency investors must consider is do crypto currencies need to be reported on the...
What are Willful Conduct and Willful Blindness in IRS FBAR Audits
What are willful conduct and willful blindness in IRS FBAR audits and court cases? It is important to begin with an understanding regarding IRS FBARs and when they are required. Any US taxpayer who has offshore bank or investment accounts (outside the United States) is required to prepare and file an...
Two US Canadian Taxpayers Fail to File FBARs
The US Court of Federal Claims found two US Canadian taxpayers fail to file FBARs resulting in summary judgment for the IRS. The couple's defense was primarily based upon the fact they had engaged a "professional tax adviser" to prepare their returns and failed to review them. The court rejected...
Are You a Foreign National Living and Working in San Diego
Are you a foreign national living and working in San Diego? Have you come into the US on an H1-B or other Visa? It is important for all foreign nationals who reside in the US for more than a few months to understand their obligations under US tax laws. One...
Failure to Comply with IRS FBAR Reporting Requirements Part of Manafort Indictment
The failure to comply with IRS FBAR reporting requirements was part of the recent Manafort indictment, but it doesn't just apply to the wealthy or powerful. The failure to fully and accurately disclose offshore bank accounts, investments, assets and real property is a challenge for many US taxpayers, and the...
FBAR Related Charges Will Put Paul Manafort Behind Bars
While facing a slew of federal charges including conspiracy against the United States the FBAR related charges will put Paul Manafort behind bars. The charges against the former campaign manager and his aid are serious in their very nature, but it is interesting that one of the central issues associated...