FBAR


FBAR Not Limited to $100,000, Willfulness Upheld

There have been a number of recent court cases involving foreign bank account or FBAR reporting penalties.  This is likely due to the significant amount of the penalty and that many do not fully appreciate the amount of the liability they face if caugh…


Reckless Conduct Sufficient for FBAR Civil Tax Penalty

It is not clear as to what level of conduct justifies the imposition of the $100,000+ foreign bank account reporting (“FBAR”) civil tax penalty. In Bedrosian v. United States, No. 15-5853 (E.D. Pa. 2017), the court considered whether reckless conduct is sufficient given the facts presented in the case. The FBAR Civil Tax Penalty The […]

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The Benefits of IRS’s Streamlined Procedures for Reporting Foreign Accounts

Given its limited resources and ability to detect foreign assets, accounts and income, the IRS has offered various voluntary programs to entice taxpayers to come clean and report this information. The IRS’s OVDP program and the more recent streamlined procedures are two examples. The Maze v. Internal Revenue Service, Nos. 15-1806 (D.D.C. 2016), highlights several[…]

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Online Payment Account Triggered FBAR Filing, Poker Websites Did Not

In Hom v. United States, No. 14-16214 (9th Cir. 2016), the court addressed whether an online payment account and whether poker websites triggered FBAR filing requirements. FBAR Filing Requirements Taxpayers with an interest in or authority over certain…


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