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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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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