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...
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...
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...
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...
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...
Initial Analysis of the Proposed Corporate Tax Plan on International Business and S Corporations
Our initial analysis of the proposed corporate tax plan on international business and S Corporations shows a mixed bag of moving pieces. Generally speaking, the plan calls for a corporate tax cut from the present rate of 35% to 20%. One interesting component is the replacement on the tax of...
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...