Did you file an application under the IRS Streamlined Domestic (Foreign) Offshore Procedures? What happens if the IRS rejects your FBAR streamlined application and claims of non-willful conduct? What actions have been taken by the IRS that concern the attorneys at Allen Barron? Let's begin with the last question first....
I Didn’t Know I needed to File an FBAR – Is That Non-Willful Conduct?
I hear it often - from dinner parties to fellow travelers to those who simply call for advice: "I didn't know I needed to file an FBAR." The next questions that follows are often: "This isn't that big of a deal is it? Can I simply catch up on my past FBARs and...