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...
Unusual Non-Willful Court Decision in Pennsylvania FBAR Case
A recent case in the United States District Court for the Eastern District of Pennsylvania has turned the recent tide of IRS victories regarding "willful versus non-willful" intent in FBAR related compliance cases. The unusual non-willful court decision found the US taxpayer was not "willful" when failing to report one...
What is Willful Blindness in IRS FBAR Cases?
What is willful blindness in IRS FBAR cases and how is the IRS attempting to use this to make non-willful FBAR violators appear to be willful? Why would this matter? The legal standard of "willful or non-willful" is an important distinction, especially as it relates to FBAR violations and penalties. ...
Jan Allen Speaks on a National IRS FBAR Panel Tomorrow
Jan Allen speaks on a national IRS FBAR panel tomorrow at 12:30 pm pacific time, 3:30 pm eastern. The topic of the expert panel discussion is "Willfulness and the IRS Disclosure Programs. Are you Compliant?" The program will answer the questions of US taxpayers and foreign nationals who live and...
The IRS Will Never Know About My Offshore Financial Accounts
We often hear clients say "The IRS will never know about my offshore financial accounts and assets," with conviction as if they are wishing it to be true. Unfortunately, the reality of today's world is much different. The truth of the matter is shocking to many people: The IRS is...
US Court of Appeals Upheld Requirement for IRS FBAR Reporting
The Sixth District of the US Court of Appeals upheld requirement for IRS FBAR reporting recently. The decision affirmed the actions of a US District Court which dismissed a complaint which challenged FATCA and the requirement to come into compliance with IRS FBAR disclosures. The lawsuit sought to prohibit...
How Can Allen Barron Better Protect You and Your FBAR Compliance
How can Allen Barron better protect you and your FBAR compliance issues with the IRS? How can Allen Barron help you come into compliance with IRS FBAR reporting requirements while keeping associated penalties and risk at a minimum? Allen Barron is uniquely positioned to provide sound counsel and comprehensive services...
IRS is Closing In on US Taxpayers with Offshore Accounts
The IRS is closing in on US taxpayers with offshore accounts thanks to the global exchange of information which has been a by-product of FATCA and the Justice Department's pursuit of Swiss banking and financial interests. The deal between the IRS and Swiss institutions ultimately led to an agreement to...
IRS FBAR Reporting Notes and Caution Regarding Streamlined Application Filings
Recently released IRS FBAR reporting notes detailed some interesting facts regarding FBAR filings since the program's inception in 2007. In 2007 the IRS received 332,000 FBARs compared to more than 1 million FBAR reports for tax year 2015. The IRS noted it has charged hundreds with tax evasion and willful...