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” […]

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Passport Revocation Update: Over 436,000 Taxpayers Meet “Certification” Criteria

Many of my readers already know that one’s US passport is in serious jeopardy if a taxpayer has what is called “seriously delinquent tax debt”.  First, some brief […]

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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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Newest IRS Campaigns – Targeting All Things Foreign, Especially NRAs

  For the past few years, the Internal Revenue Service’s (IRS) Large Business and International (LB&I) Division has been shifting to a new audit strategy known as “campaigns.” […]

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