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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...

US Expats a New IRS Target for FBAR Violations

What makes US expats a new IRS target for FBAR violations and undisclosed offshore assets?  The IRS is instituting a new whistle-blower campaign for those who might help US expats and other US taxpayer clients.  Allen Barron provides attorney-client protections for those who are working on the disclosure of foreign...