Posts in Hughes Court Splits Decision on FBAR Willful & Non-Willfulness

Featured FBAR Blog Post

Meet Our OVDP Lawyers for FBAR/FATCA: Offshore Tax Specialist Team

   OVDP Lawyers The Offshore Voluntary Disclosure Program was great program designed to bring US Taxpayers with undisclosed offshore […]
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Delinquent FBAR Submission Procedures for Late-Filing 2022

  Delinquent FBAR Late-Filing Submission Procedures The Internal Revenue Service continues to move full steam ahead on enforcement matters involving […]
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Willful FBAR Penalty Guide for Assessing and Calculating Penalties

Willfulness FBAR Penalty Roadmap for Taxpayers A civil willful FBAR violation does not mean a person violated any criminal law. […]
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District Court FBAR Penalty Calculation Violated APA, Schwarzbaum

District Court FBAR Penalty Calculation Violated APA As we have written about extensively here and here, the international tax law […]
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Lawyer & Tax Prep Fees for Delinquent FBAR & FATCA: Flat-Fee or Hourly?

Attorney Fees for FBAR Lawyers Attorney Fees for FBAR Lawyers: With the IRS having both closed OVDP (2018) and ended DIIRSP […]
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FBAR Basics: Avoid Foreign Account Reporting FinCEN 114 Problems

  FBAR Basics The FBAR refers to Foreign Bank and Financial Account Reporting on FinCEN (Financial Crimes Enforcement Network) Form […]
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New Civil Willful FBAR Regulation 31 CFR § 1010.820 Explained

The New Willful FBAR Regulation Update Explained Recently, the Financial Crimes Enforcement Network (FinCEN) released an update to the Civil […]
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Fighting Non-Willful FBAR Penalties: A 10-Step Roadmap

Fighting Non-Willful FBAR Penalties Against IRS In general, US Taxpayers have a very difficult time with the IRS enforcement of […]
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