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FBAR
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Webb & Morton PLLC Blog
Reckless Review of Tax Return and Willful FBAR Penalties
By Jason Morton
In March 2021, in U.S. v. Gentges, the court held that a taxpayer filing an erroneous tax return – despite his carelessness in reviewing it before he signed it –…
Tax
Missed the April 15 FBAR Due Date? Don’t Fret it
Missed the April 15 FBAR Due Date? Missed the April 15 FBAR Due Date? Missed the April 15 FBAR Due Date? Even though the IRS continued the due date for…
Tax
Eleventh Circuit Court Affirms Reckless Disregard FBAR Willful Penalty
Eleventh Circuit Appeals Affirms Lower Standard FBAR Willfulness Eleventh Circuit Appeals Affirms Lower Standard FBAR Willfulness Eleventh Circuit Appeals Affirms Lower Standard FBAR Willfulness: When it comes to willful FBAR…
Banking, Finance and Securities
How International FBAR Penalties have Evolved in 2021
FBAR Penalties FBAR Penalties FBAR Penalties: In recent years, the Internal Revenue Service has significantly increased the assessment and enforcement of FBAR Penalties for undisclosed foreign bank and financial accounts.…
Tax
Court Rules Swiss Numbered Account Willful FBAR Penalty
By Board-Certified Tax Law Specialist
Court of Claims Holds Numbered Account Willful FBAR Penalty Court of Claims Holds Numbered Account Willful FBAR Penalty Court of Claims Holds Numbered Account Willful FBAR Penalty: In the FBAR…
Tax
Court Finds FBAR Willfulness Penalty in Numbered Account Case: Landa
By Board-Certified Tax Law Specialist
Court of Claims Holds Numbered Account Willful FBAR Penalty Court of Claims Holds Numbered Account Willful FBAR Penalty Court of Claims Holds Numbered Account Willful FBAR Penalty: In the FBAR…
Tax
Court of Claims Finds Willful FBAR Swiss Account Violation
Claims Court Finds Willful FBAR Swiss Account Violation & No Trust Claims Court Finds Willful FBAR Swiss Account Violation Court Finds Willful FBAR & Swiss Number Account Not a Trust:…
Webb & Morton PLLC Blog
FBAR Penalty – Per FBAR Due, Not Per Account
By Jason Morton
In a case of first impression, the Court of Appeals for the Ninth Circuit ruled that the IRS can impose only one non-willful penalty under 31 USC 5321(a)(5)(A) when an…
Tax
FBAR Instructions: International Foreign Account Guide
By Board-Certified Tax Law Specialist
FBAR Instructions FBAR Instructions FBAR Instructions: The IRS and FinCEN instructions for filing the FBAR can be confusing. It is required to be filed by US Persons, but US persons…
U.S. Income Tax for Expatriates, Nonresidents & U.S. International Tax Matters
FBAR Form 114 Filing Deadline has not been extended – but there is an automatic Extension
With the extension of the individual filing deadline to May 17, 2021, practitioners have been asking if the FBAR filing deadline was also extended. The assumption for many was that,…