An International Tax Blog: Legal News & Updated Information

All About Foreign Information Tax Returns & IRS Penalty Basics

Contents1 Everything About IRS Foreign Information Tax Return Penalties 2 The Basics of Foreign Information Tax Return3 What is a ‘Foreign Information Return’4 Who Must File a Foreign Information Return5 What About Making a Treaty Election?6 Which Foreign Assets are Reportable?7 Which IRS Forms are Required […]

by International Tax Lawyers

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

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

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

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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