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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...

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...

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...

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...