You will need to get a tax litigation attorney’s opinion on whether or not you willfully failed to file Foreign Bank Account Reports (FBARs) and report foreign income on your tax return. The answer to this question has several consequences, including the following: Non-willful FBAR violations carry a $12,459 penalty…
Taxpayers with funds in offshore accounts may wish to repatriate their funds by bringing them back to the U.S. and avoid any future Foreign Bank Account Report (FBAR) compliance issues. While this may prevent any future offshore bank account problems, it does not stop the IRS from discovering any past…
There is no specific designation as an “FBAR attorney”, but many taxpayers with undisclosed foreign financial accounts need to talk to someone with FBAR experience about their potential liability and what actions they can take to mitigate risks. A good FBAR attorney is really just a tax attorney who has…
The IRS has the authority to impose civil and criminal penalties for the failure to file Foreign Bank Account Reports (FBARs), but it is has the authority to impose lesser penalties, or none at all, in certain cases. If there is a reasonable cause for your FBAR violations, and your…
The failure to file Foreign Bank Account Reports (FBARs) can result in large penalties, but there are two separate penalties structures for willful and non-willful conduct. If your conduct is determined to be willful, you could have to pay $100,000 or 50 percent of the balance of the offshore account.…
The IRS streamlined filing compliance procedures and the Offshore Voluntary Disclosure Program (OVDP) are two different methods that can be used to resolve your offshore bank account problems. Taxpayers who have not filed a Report of Foreign Bank and Financial Accounts (FBAR) or reported their income from overseas financial accounts…