The Sky’s the Limit: FBAR Penalty Win for IRS – Recent Case Upholds 50% of Account Balance

I have been keeping readers up to date with the current controversy surrounding imposition of an FBAR penalty for “willful” violations.  Two courts have limited the FBAR “willfulness” […]

Read More…

FBAR “Willful” Penalty: Recent Case, Taxpayer “Charged With Knowledge”

Offshore bank accounts file

I blogged recently about the fact that mounting court cases have given the stamp of approval for the Government to meet a lower “burden of proof” in demonstrating […]

Read More…

US Tax Perils of International Community Property

US tax liabilities and requirements to file US tax and information returns are impacted by community property laws that exist in many foreign countries across the globe.  Today’s […]

Read More…