FBAR Willful Penalties (Updated for 2019-2020)

FBAR Willful Penalty: The IRS FBAR Willful Penalty can be devastating. In recent years, the IRS has taken an aggressive stance against U.S. persons who are out of compliance for offshore assets, accounts, investments or income. To date, the IRS has not developed a bright-line test for “willfulness.” Moreover, the term willfulness is not limited…


Delinquent FBAR (2018) – Foreign Accounts & Offshore Disclosure

Delinquent FBAR (2018) – Foreign Accounts & Offshore Disclosure Filing the FBAR when you have Foreign Accounts is a very important aspect of IRS International Tax Compliance. Why?  Because the penalties that the IRS can issue for non-filing, or improper delinquent filing and reporting of foreign bank accounts far exceed anything you could have ever…


FBAR Offshore Penalty of $14M – Tax Scam from Korea to Switzerland

FBAR Offshore Penalties Over the past week, we received numerous inquiries as a result of a recent $14 million penalty (and potential prison time) that was issued against a South Korean citizen who was a Legal Permanent Resident of the United States (Connecticut). (Partner Jenny Golding is originally from South Korea and we represent numerous clients…


How Do FBAR Attorneys Help with Foreign Account Disclosure?

What Does an FBAR Attorney do? FBAR reporting is part of IRS offshore disclosure, and the Internal Revenue Service has developed many different offshore voluntary disclosure program options for individuals who have not properly reported their foreign accounts. IRS Offshore Disclosure Programs are designed to bring individuals, businesses, and estates into compliance for prior-year failures…