An International Tax Blog: Legal News & Updated Information

Everything About FBAR Penalties You Must Know

Everything About FBAR Penalties You Should Know (Examples)

Contents1 FBAR Penalty Overview2 First, Non-Willful vs Willful Penalties3 Criminal FBAR Penalties are Rare4 Failure to File (Non-Willful)5 Missed an Account (Non-Willful)6 Late-Filing (Non-Willful) vs Quiet Disclosure7 Failure to File (Civil Willful)8 Failure to File (Criminal)9 Late-Filing Disclosure Options10 Streamlined Filing Compliance Procedures (SFCP, Non-Willful)11 Streamlined […]
by International Tax Lawyers
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Board-Certified Tax Law Specialist

What is a Board-Certified Tax Law Specialist (How to Spot a Fake)

  Contents1 Board-Certified Tax Law Specialist Summary2 Becoming a California (Board-Certified) Tax Specialist3 Less Than 350 Board-Certified Tax Law Specialists in California4 Is Your Lawyer Falsely Representing That They Are a Board-Certified Tax Lawyer Specialist?5 Tax Attorney Marketing Gimmicks6 Need Help Finding an Experienced Offshore Tax Attorney?7 […]
by International Tax Lawyers
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Understanding FBAR vs FATCA: What are the Key Differences?

Comparing FBAR vs. FATCA (2026): Key Differences Explained

    Contents1 FBAR & FATCA 2 FBAR (5 Key Facts)3 FBAR Reporting is Not a New Form4 FBAR Has a Much Lower Threshold5 FBAR Is Filed Separately; FATCA Is Filed With the Return6 FATCA (5 Key Facts)7 FATCA Compliance Involves Reciprocal Global Reporting8 FATCA Requires Having […]
by International Tax Lawyers
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Recklessness FBAR Noncompliance Leads to Willful Penalty

Recklessness FBAR Noncompliance Leads to Willful Penalty 2026

Contents1 Reckless FBAR Explained2 First, How is Reckless FBAR Defined?3 United States v. Reyes4 Failure to Notify Their Accountant of Foreign Accounts5 VDP and Withdrawal from the Program6 IRS Findings7 Explaining Reckless Disregard in the Context of Willfulness 8 The Court Rejects Reyeses’ Arguments 9 Other Cases (Pre-2026)10 […]
by International Tax Lawyers
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Do You Have Foreign Accounts or Assets: Reviewing the Steps

Time for Your 2025 Annual Foreign Account Review

Contents1 Do You Have Foreign Accounts or Assets: 2025 FBAR Review2 Do You Have Foreign Accounts or Assets?3 What Other Types of Foreign Investments Does the Taxpayer Have?4 What is the Maximum Value of the Foreign Accounts and Assets?5 Which Forms Does the Taxpayer Have to […]
by International Tax Lawyers
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