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Posts Tagged FBAR penalties

IRS Hands Down Record Penalty in FBAR Case

A few days we ago we wrote about the expected guilty plea by Beanie Baby creator Ty Warner. The feds charged Warner with  tax evasion. Prosecutors say he failed to report offshore Swiss accounts and file required FBAR forms. U.S. taxpayers must annually report their offshore financial assets if at any point in the year [...]

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Proving Willfulness in FBAR Penalty Cases

[Ed. Note - several days ago we wrote a post about willfulness as it relates to FBAR penalties. That article gave specific examples of what constitutes willful behavior. Since that post was written, we received several inquiries regarding the legal standards. Readers interested in this topic should read both posts.] As regular readers of this [...]

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FBAR Penalties and the Definition of “Willful”

U.S. taxpayers are required to report offshore financial holdings when the aggregate balance of those assets exceeds $10,000. Even if your foreign brokerage account exceeds $10,000 in value for just 1 day, federal law requires the account be reported on a Report of Foreign Bank and Financial Accounts – FBAR for short. The FBAR penalties [...]

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Do You Have The Right To Rely on IRS Forms? Court Says “Maybe” – FBAR Post

A federal jury in South Bend, Indiana convicted James Simon of filing false tax returns and of failing to file FBARs. As regular readers of this blog know, the willful failure to file an FBAR is a felony. Following his conviction, Simon appealed. In a lengthy opinion, the US. Seventh Circuit Court of Appeals upheld [...]

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FBAR Post – US Swiss Tax Deal Imminent

There have been many false starts in the long battle between the IRS and proponents of Swiss banking secrecy. Even after both Swiss banks and the Swiss finance ministry caved to pressure from Washington, the Swiss parliament stepped in to prevent the banks from making wholesale disclosures to the IRS. Now a deal between the [...]

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