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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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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