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...
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...
The Process of Understanding IRS FBAR Compliance
There are still many US taxpayers who are in the process of understanding IRS FBAR compliance and the genuine risk their activities (or lack of compliance) will come to light. A US taxpayer, include all citizens and those who work or live for more than six months and one day...
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...
The US Tax Impact of Opening a Foreign Account
What is the US tax impact of opening a foreign account for a US taxpayer including foreign nationals who live and work in the United States? The requirement for US taxpayers to report offshore accounts has been around for quite some time. In 2004, the IRS added penalties for non-willful...
How Does the IRS Define Willfulness for FBAR Audit Purposes
How does the IRS define willfulness in terms of IRS FBAR compliance? When will the actions of a US taxpayer amount to a "willful or non-willful" evasion of IRS FBAR responsibilities? If you have offshore bank or investment accounts you have probably heard by now that you are required to...
Wall Street Journal Warns Offshore Account Holders to Fear the IRS
A major US financial newspaper today echoed Allen Barron's repeated warnings to offshore account holders to fear the IRS and impending IRS audits. The Wall Street Journal (WSJ) today issued a daunting warning to US taxpayers with offshore bank accounts, investment accounts and assets: "Are You Hiding Money Overseas from...