What is willful blindness according to the IRS? How is this important in tax cases involving unreported or under-reported income, disclosure of offshore assets and income, FinCEN Form 114 (more commonly referred to as an "FBAR"), and even digital currencies and Non-Fungible Tokens (NFTs)? In an internal IRS memorandum from...
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...