Following a string of other similar decisions, the Ninth Court Court of Appeals in United States v. Boyd finds that the non-willful FBAR penalty is assessed by form and not by account. In doing so, it reversed the lower court’s…

In at least the second such instance that we’re aware of, the Government has brought charges related to filing a false streamlined submission, among other things.

Excerpt below from the DOJ press release:

A federal grand jury in Alexandria,…

After a district court in Texas recently held that penalties for the non-willful failure to file an FBAR is be assessed by form (and not by the number accounts), the District Court of Connecticut came to a similar decision in…

The IRS Small Business & Self-Employed Division updated guidance (SBSE-04-1120-0074) for foreign bank account report compliance activity due to the COVID-19 pandemic. A text of the document appears below:
This memorandum issues updated guidance for Report of Foreign…

In a recent case before the U.S. Court of Federal Claims, two married taxpayers appeared pro se in challenging the assessment of passive foreign investment company (PFIC) income taxes.  David C. Shnier et ux. v. United States; No. 1:18-cv-01257
Taxpayers…

The IRS recently announced an LB&I campaign that targets nonresidents who own U.S. rental properties. Based on past experience, IRS campaigns should be taken seriously. The IRS will prioritize and act on them.

“Practice Area: Withholding and International Individual Compliance…

We had written about the Bittner case before. The IRS had sought to reduce to judgment about $3M of non-willful FBAR penalties, which had been assessed per account.
The taxpayer countered that non-willful FBAR penalties should have been assessed per…