Offshore Account Holders Should Beware: The IRS Is Still Coming
By Christopher M. Ferguson AICPA Tax Insider Newsletter October 25, 2018 The recent end of the OVDP is not the end of IRS enforcement of undisclosed offshore accounts. For most of the past decade, the IRS has maintained a safe harbor for taxpayers who want to
Federal Courts Disagree On Whether The 50% Willful FBAR Penalty Is Illegal
By: Bryan C. Skarlatos & Michael Sardar June – July 2018 Edition Journal of Tax Practice & Procedure Imagine a situation in which Congress passed a statute establishing civil penalties for certain conduct, including the maximum penalty that may be imposed for such conduct, and delegated enforcement of
FBAR Filing For Non-U.S. Citizens
By Wilda Lin The CPA Journal October 2018 Edition Reports of Foreign Financial and Bank Accounts (FBAR) have gained prominence since the Department of Justice began investigating the accounts of Swiss banks, starting with UBS almost a decade ago. Who must file FBARs? Many people