Statute
FBAR
239 published works
Tax
Streamlined Domestic 5% Title 26 Miscellaneous Offshore Penalty
By Golding & Golding, Board-Certified Tax Law Specialist
Form 14654 Penalty ExampleHow to CalculatePractice Pointer Step 1: Evaluate your Accounts & AssetsThere are many different accounts and assets that may be included in the computation. Two of the…
U.S. Income Tax for Expatriates, Nonresidents & U.S. International Tax Matters
Are Virtual Currencies such as Bitcoin reportable on FBAR forms (form 114)? – the answer is sometimes yes.
The IRS does not consider virtual currencies such as BItcoin to be the same as cash or money. They consider it to be an asset to be treated for tax…
Tax Withholding & Reporting
Is a Circuit Split Brewing over FBAR Willfulness Penalties?
A question appears at the bottom of Schedule B (Interest and Dividend Income) of the Form 1040 (U.S. Individual Income Tax Return) that asks individual taxpayers if during the taxable…
Tax Withholding & Reporting
<i>Garrity</i> Ruling is Latest in Growing Debate over Civil Penalties for FBAR Violations
The U.S. District Court for the District of Connecticut has joined a growing debate among lower courts regarding the appropriate civil penalty applicable to willful FBAR violations through its ruling…
Asset Search Blog
Money Laundering Indicators In Dan Horsky’s Case
By Fred Abrams
https://www.youtube.com/watch?v=R37tVCqNC1Q In USA v Dan Horsky prosecutors claimed Mr. Horsky had hidden money in Zurich, Switzerland at Credit Suisse and at other offshore banks. The gravamen of the allegations at…
Rubin On Tax
FBAR “Willfulness” Decision
A substantial penalty applies for those who willfully fail to report a foreign account on an FBAR. A recent 2nd Circuit Court of Appeals opinion weighed in on two uncertainties…
Tax Controversy Report
FinCEN Grants Further Extension of FBAR Deadline for Certain Financial Professionals
On December 4, 2018, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced a further extension of time for Report of Foreign Bank and Financial Accounts (FBAR) filings for certain…
International Financial Law Prof Blog
IRS’ Confiscatory Percentage Based FBAR Penalties Ruled Illegal By Court
Jack Townshend analyzes the following case: In United States v. Colliot (W.D. Texas No. AU-16-CA-01281-SS), a case brought by the U.S. to obtain judgment on an FBAR willful penalty, the Court granted…
U.S. Income Tax for Expatriates, Nonresidents & U.S. International Tax Matters
WHEN TO REPORT DIGITAL CURRENCY ON YOUR FBAR form 114
The IRS says it is not bound by oral advice. Ignoring that rule, we did received the statement below from an IRS agent by email. Digital currency like Bitcoin would…
Tax Controversy Report
Internal Revenue Service Reminds Taxpayers to Report Offshore Bank Accounts on FBAR Form
The Internal Revenue Service has issued its annual reminder to taxpayers that they report their foreign assets on their individual tax returns due on April 17, 2018. Individuals with offshore…