201904.06
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MMA Fighter Wins by Settlement in FBAR Dispute with the IRS (2019)

MMA Fighter Wins by Settlement in FBAR Dispute with the IRS (2019) - Golding & Golding

MMA Fighter Wins by Settlement in FBAR Dispute with the IRS (2019) – Golding & Golding

MMA Fighter Wins by Settlement in FBAR Dispute with the IRS (2019)

MMA Fighter Settles FBAR Dispute: MMA Fighter Royce Gracie battled the IRS on the issue of FBAR willful penalties, and wins by settlement before an appeal ruling was issued.

While it may not be a win by knockout, chances are the settlement terms will be better than the initial penalty amount the IRS was seeking.

The original Golding & Golding article can be found here.

FBAR Appeal

The matter was on appeal, but the Internal Revenue Service and former MMA Champion settled their differences outside the ring, before a decision could be issued.

On April 2, 2019 the parties filed a:

STIPULATION to Dismiss Case pursuant to Settlement filed by Plaintiff United States of America and Proposed Order on Stipulation to Dismiss by Reason of Settlement

Later that same day, the court issued a


“ORDER ON STIPULATION TO DISMISS BY REASON OF SETTLEMENT by Magistrate Judge Alexander F. MacKinnon, re Stipulation to Dismiss Case66 . See document for details.”


*The full terms of the settlement agreement are not currently available.

Non-Compliance with U.S. Tax Law

Whether it is because you did not you had to report foreign accounts, thought you were below the threshold for filing, did not realize non-bank accounts were required to be reported, and/or have other unreported income, accounts, investments or assets – we can help.

What Can You Do?

Presuming the money was from legal sources, your best options are either the Traditional IRS Voluntary Disclosure Program, or one of the Streamlined Offshore Disclosure Programs.

Golding & Golding, A PLC

We have successfully represented clients in more than 1000 streamlined and voluntary disclosure submissions nationwide, and in over 70-different countries.

We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants, and Financial Professionals across the globe.

International Tax Lawyers - Golding & Golding, A PLC

International Tax Lawyers - Golding & Golding, A PLC

Golding & Golding: Our international tax lawyers practice exclusively in the area of IRS Offshore & Voluntary Disclosure. We represent clients in 70+ different countries. Managing Partner Sean M. Golding is a Board-Certified Tax Law Specialist Attorney (a designation earned by < 1% of attorneys nationwide.). He leads a full-service offshore disclosure & tax law firm. Sean and his team have represented thousands of clients nationwide & worldwide in all aspects of IRS offshore & voluntary disclosure and compliance during his 20-year career as an Attorney.

Sean holds a Master's in Tax Law from one of the top Tax LL.M. programs in the country at the University of Denver. He has also earned the prestigious IRS Enrolled Agent credential. Mr. Golding's articles have been referenced in such publications as the Washington Post, Forbes, Nolo, and various Law Journals nationwide.
International Tax Lawyers - Golding & Golding, A PLC

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