Statute
FBAR
239 published works
Tax, Trusts & Estates Law
IRS to Close Offshore Voluntary Disclosure Program this September
By Steven M. Saraisky, Reuben Muller
On March 13, 2018, the IRS announced that the Offshore Voluntary Disclosure Program (OVDP) will be closing on September 28, 2018. This program has been in place since 2009. In…
Tax Controversy Report
Offshore Accountholders Beware: New DOJ Sentencing Policy for FBAR Cases Is a Game-Changer
The Justice Department’s Tax Division has recently announced a major policy shift that will invariably result in longer jail sentences for individuals convicted of failing to report their offshore bank…
Tax Controversy Report
FinCEN Clarifies Upcoming FBAR Due Date for Calendar Year 2017
Today the Treasury Department's Financial Crimes Enforcement Network posted a "FBAR Due Date Clarification" on its website, which confirms that the annual filing deadline for FinCEN Form 114 (commonly referred to as…
Tax Controversy Report
FinCEN Announces Yet Another FBAR Filing Extension for Certain Financial Professionals
Last week the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) again extended the deadline for certain financial professionals to file foreign bank accounting reporting forms known as FBARs. In FinCEN…
Asset Search Blog
3 Goals For Your Asset Search
By Fred Abrams
Searching for an adversary's hidden assets can be like tracking a shell-game-operator. In USA v. Khalili for instance, Mr. Dan Farhad Khalili was accused of hiding assets & undeclared revenue…
Disputing Tax
‘Willfulness’ In Civil FBAR Cases Comes Down To The Facts
By Kat Gregor
In a recent Law360 article, "'Willfulness' In Civil FBAR Cases Comes Down To The Facts,” Kat Gregor commented on a recent court decision allowing a pharmaceutical company CEO to escape…
Tax Controversy 360
Manafort Indictment Is a Good Reminder of FBAR Disclosure Requirements
By Laura L. Gavioli, PC, Roger J. Jones, Andrew R. Roberson, Kevin Spencer, McDermott Will & Emery
On October 30, 2017, Paul Manafort Jr. was indicted for concealing his interests in several foreign bank accounts, as well as tax evasion and a host of other criminal charges. …
International Financial Law Prof Blog
Green Card Holder Pleads Guilty of Failing to File FBAR and Report UBS Account, Will Pay More than Half the Assets in FBAR and Tax Penalties
A Greenwich, Connecticut man pleaded guilty October 26, 2017, to failing to report funds he maintained in foreign bank accounts to the Department of Treasury, announced Acting Deputy Assistant Attorney General…
Tax Controversy Report
FinCEN Provides FBAR Relief to Victims of the California Wildfires
The Treasury Department's Financial Crimes Enforcement Network (FinCEN) announced today that California wildfire victims in affected areas of California have until January 31, 2018, to file their Report of Foreign…
Tax Controversy Report
FinCEN Provides Updated FBAR-Filing Relief to Victims of Hurricanes Harvey, Irma, and Maria
The Treasury Department's Financial Crimes Enforcement Network (FinCEN) today updated two previous notices regarding FBAR-filing relief to victims of the recent hurricanes. Extension filers have until January 31, 2018 to file…