Can Taxpayer Prove her FBAR Violation was Unintentional

Contents1 How are FBAR Violations Issued2 Summary Judgment and FBAR3 Can Defendant Show her actions were Unintentional?4 What are Defendant’s Arguments?5 FBAR Attorney Specialist – Golding & Golding (Board-Certified) Can a California Resident Prove her FBAR Violation was Unintentional The case at issue is U.S. vs. Fariba Ely Cohen. How are FBAR Violations Issued So…


FATCA Update for Canada: 900,000 Accounts of U.S. Persons Sent to IRS

Contents1 Canada Sends Bank Information for 900,000 Accounts to IRS2 Foreign Bank Account Lawyers – Golding & Golding (Board-Certified) Canada Turns Over 900,000 Accounts to IRS: In accordance with FATCA (Foreign Account Tax Compliance Act), the U.S. has come into possession of nearly 1M more Canadian Accounts that are owned by U.S. persons. Canada Sends…


Federal Circuit Court of Appeals Upholds FBAR Willful Penalty

Contents1 FBAR Willfulness2 U.S. v. Norman 3 Filing Requirement4 Willfulness FBAR Penalty5 Facts Support the Lower Court Ruling6 “No Knowledge” Defense Rejected7 $100,000 Penalty Cap Rejected8 Willful FBAR Penalty Lawyers – Golding & Golding (Board-Certified) Federal Circuit Court of Appeals Upholds FBAR Willful Penalty Federal Circuit Court of Appeals Upholds FBAR Willful Penalty: In a major setback…


IRS Can Refer Unreported Overseas Accounts for Criminal Investigation

The enforcement of overseas account and asset reporting is a key priority for the IRS. With the recent trend of overseas compliance and enforcement, the IRS has increased the number of referrals to the special agents. After the Special Agents conduct their own research, if they reach the conclusion that a crime was committed, it…


Former CPA Has Been Indicted for Multiple FBAR Violations

Contents1 Booker was a Prior CPA who Filed an SDOP2 The U.S. Requires U.S. and Foreign Income be Reported3 Former CPA Mr. Booker Maintained Foreign Accounts4 Mr. Booker was Outed by His Own Swiss Bank5 Mr. Booker only “Partially Reported” his Foreign Accounts6 Defendant Submits False Documents Through the Streamlined Program7 How to Qualify for…