Tag: FBAR
Voluntary Disclosure options for taxpayers after the closing of the OVDP
By: Tiffany D. Bell When the IRS closed the 2014 OVDP last fall, which had provided an avenue for taxpayers to come into compliance with any past offshore tax and information reporting, it left many taxpayers and tax practitioners wondering, what do we do now? Since 2009, the IRS has offered taxpayers a variety of voluntary disclosure programs within which
Think the IRS is quiet during the Shutdown? Think Again! Another Form 3520 Trap for the Unwary
By: Randall P. Andreozzi Things are emerging from the abyss that is the longest government shutdown in United States history. Yes, there exist some things so resilient, so pervasive, so constant they can survive and proliferate even in a governmental vacuum. Our friends who are U. S. citizens living abroad know this species all too well and are likely collectively
FBAR Penalties – The Government’s Coin-Flip Burden of Proof on Willfulness
By: Heather L. Marello, Esq. The Bank Secrecy Act of 1970, Pub. L. 91-507, 84 Stat 114 (Oct. 26, 1970), addressed the government’s desire to monitor the use of foreign bank accounts for illegal activities by authorizing the Secretary of the Treasury to require U.S. citizens, residents, and others to “keep records, file reports, or keep records and file reports,