FBAR Amnesty Program

FBAR Amnesty: The IRS has developed multiple foreign bank account program amnesty options for FBAR and FATCA related non-compliance. These programs are available to Taxpayers worldwide. The purpose of amnesty is to assist U.S. Persons with getting into offshore compliance. Generally, international tax compliance involves IRS Offshore Disclosure of unreported foreign accounts, assets, or investments.

The FBAR penalties for unreported foreign accounts can be substantial. Penalties can be civil or criminal, and willful or non-willful.

Golding & Golding is an International Tax Law Firm.

Our Team is led by a Board Certified Tax Lawyer Specialist, and our FBAR Lawyers have worked with thousands of clients across the globe.

FBAR Amnesty Program 2020: New Options for Taxpayers

FBAR Amnesty Program 2020: New Options for Taxpayers

The FBAR Amnesty rules are complex. The FBAR is Report of Foreign Bank and Financial Account form. It is used to report accounts on FinCEN Form 114. There are many aspects to foreign account reporting, which we will discuss — as well as review the different options available to taxpayers.

2019 Amnesty

FBAR Amnesty 2019 has changed, due to the ending of the traditional OVDP program, and updated new procedures for both domestic and offshore submissions.

2018 Amnesty

If you are seeking FBAR Amnesty 2018 for prior year FBAR non-compliance, you can use this article to assist you with getting into compliance for 2019 and prior years.

2017 Amnesty

If you are seeking FBAR Amnesty 2017 for prior year FBAR non-compliance, you can use this article to assist you with getting into compliance for 2019 and prior years.

2016 Amnesty

If you are seeking FBAR Amnesty 2016 for prior year FBAR non-compliance, you can use this article to assist you with getting into compliance for 2019 and prior years.

FBAR Amnesty 2015

If you are seeking FBAR Amnesty 2015 or prior year FBAR non-compliance, you can use this article to assist you with getting into compliance for 2019 and prior years.

Civil Fines & Penalties

Civil FBAR Penalties are limited to monetary penalties.

A civil FBAR Penalty is a penalty that is focused on monetary fines or warning letters (waivers) — without any risk of criminal investigation or prosecution.

Penalties for Civil FBAR can be Broken down into two (2) categories:

  • Willful FBAR Penalties
  • Non-Willful FBAR Penalties

Non-Willful Violations

These FBAR Penalties are typically the least severe penalties. An FBAR non-willful penalty is a “lower-level” penalty for not filing the FBAR.Non-willful penalties can be high, BUT, typically they are not as high as willful penalties.

Willful Violations

The Willful FBAR Penalty is typically more severe. An FBAR Willful Penalty is penalty for acting willful, willfully blind, or with reckless disregard in not filing the FBAR. We have provided detailed explanations and analyses in our free International Tax Law library about these different terms, and what they mean.

Criminal Fines & Penalties

Criminal FBAR Penalties may include monetary penalties and incarceration. This is when the IRS refers the matter to the Department of Justice (DOJ) or other 3 letter government faction for criminal investigation and possible prosecution.

These are not very common, but unfortunately they are on the rise.

Golding & Golding: About Our International Tax Law Firm

Golding & Golding specializes exclusively in international tax, and specifically IRS offshore disclosure

We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants, and Financial Professionals across the globe. Our attorneys have worked with thousands of clients on offshore disclosure matters, including FATCA & FBAR.

Each case is led by a Board-Certified Tax Law Specialist with 20 years of experience, and the entire matter (tax and legal) is handled by our team, in-house.

*Please beware of copycat tax and law firms misleading the public about their credentials and experience.

Less than 1% of Tax Attorneys Nationwide Are Certified Specialists

Sean M. Golding is one of less than 350 Attorneys (out of more than 200,000 practicing California Attorneys) to earn the Certified Tax Law Specialist credential. The credential is awarded to less than 1% of Attorneys.

Recent Golding & Golding Case Highlights

  • We represented a client in an 8-figure disclosure that spanned 7 countries.
  • We represented a high-net-worth client to facilitate a complex expatriation with offshore disclosure.
  • We represented an overseas family with bringing multiple businesses & personal investments into U.S. tax and offshore compliance.
  • We took over a case from a small firm that unsuccessfully submitted multiple clients to IRS Offshore Disclosure.
  • We successfully completed several recent disclosures for clients with assets ranging from $50,000 – $7,000,000+.

How to Hire Experienced Offshore Counsel?

Generally, experienced attorneys in this field will have the following credentials/experience:

  • 20-years experience as a practicing attorney
  • Extensive litigation, high-stakes audit and trial experience
  • Board Certified Tax Law Specialist credential
  • Master’s of Tax Law (LL.M.)
  • Dually Licensed as an EA (Enrolled Agent) or CPA

Interested in Learning More about Golding & Golding?

No matter where in the world you reside, our international tax team can get you IRS offshore compliant. 

Golding & Golding specializes in FBAR and FATCA. Contact our firm today for assistance with getting compliant.

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