Golding & Golding, A PLC

FBAR Penalties May Survive Death FBAR Penalties May Survive Death FBAR Penalties May Survive Death: There have a slew of new FBAR court rulings on matters involving the Foreign Bank Account Reporting (FinCEN Form 114) and how penalties should issued and upheld. When a Defendant’s back is against the wall, they have to try and find anyway they can to limit or minimize the FBAR Penalties — which can be astronomical. One way…
What is the Tax Evasion Federal Crime Definition? What is the Crime of Tax Evasion   What is the Tax Evasion Federal Crime Definition: It is not uncommon that when a US Taxpayer believes they have run afoul of the law on matters involving their US taxes — they automatically believe they are  guilty of the tax crime of tax evasion. But, more often than not a Taxpayer who may have violated the tax code is…
Court Affirms Willful FBAR Fines Can Exceed Regulation Maximum Court Affirms Willful FBAR Fines Can Exceed Regulation Maximum Court Affirms Willful FBAR Fines Can Exceed Regulation Maximum: In a recent FBAR case in the U.S. Court of Appeals for the Second Circuit, the Court of Appeals affirmed the District Court’s ruling that willful FBAR Penalties are NOT limited to $100,000 per year. Appellant’s argument (which has been pursued by other Taxpayers across the nation as…
Court Authorizes IRS for Records Relating to Panamanian Offshore Service Court Authorizes IRS for Records Relating to Panamanian Offshore Service Court Authorizes IRS for Records Relating to Panamanian Offshore Service: Just because the debacle that was the Panama Papers was yesterday’s news — does not mean the participants in the alleged scheme are out of the woods just yet. In fact, the IRS has just turned up the heat in its quest to obtain information…
Outdated FBAR Regulation Does Not Limit Willful Penalties Outdated FBAR Regulation Does Not Limit Foreign Account Penalties Outdated FBAR Regulation Does Not Limit Willful Foreign Account Penalties: In a recent FBAR case in the U.S. Court of Appeals for the Second Circuit, the Court of Appeals affirmed the District Court’s ruling that willful FBAR Penalties are NOT limited to $100,000 per year. Appellant’s argument (which has been pursued by other Taxpayers across the nation as…
Must Taxpayer Repatriate Foreign Money for FBAR Fines? Must Taxpayer Repatriate Foreign Money for FBAR Must Taxpayer Repatriate Foreign Money for FBAR Fines? In the case of US v Schwarzbaum, the Defendant was hit with a $13M judgment for FBAR Penalties – which the Defendant is still appealing. In the meantime, the US Government wants to move forward with enforcement, and seeks to collection of the judgment — by forcing Defendant to repatriate the…