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 […]

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The J5 International Tax Hunt is On….

Many countries are waking up to the fact that offshore structures, financial instruments, cryptocurrency and other advances in technology, when inappropriately used, are fast outwitting their tax collectors. […]

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Form 5472 – Everything You Need To Know (Part II)

Last week’s blog post covered some basics about Form 5472, including how the Form helps the US Internal Revenue Service (IRS) learn about foreign-owned businesses in the US […]

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Form 5472 – Everything You Need To Know (Part I)

Close up of hands filling in a tax form

This tax filing season brought a wave of questions about Form 5472.  Interest in this complex form was renewed because of recent Treasury Regulations requiring that it be […]

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