U.S. citizens and residents with financial interests in foreign accounts that exceed $10,000 at any time in a year must file an FBAR. The failure to file an FBAR can be costly. If the government shows ...

The Report of Foreign Bank and Financial Accounts (FinCEN Form 114) commonly called the FBAR is a crucial reporting requirement for U.S. persons with foreign financial accounts. With the deadline for ...

The Tax Court held that FBAR penalties are not a tax imposed by the Code and, therefore, are not subject to the requirements of Secs. 6320 and 6330. Facts: Stephen C. and Judy A. Jenner were assessed ...

Over the past 10 years, this column has detailed the Internal Revenue Service’s aggressive pursuit of taxpayers with undisclosed offshore accounts. In addition to criminal prosecutions, the IRS’s ...

A district court held that FBAR penalties accrue on the date the FBAR form is due and that an individual’s death did not extinguish these penalties or make them excessive under the Eighth Amendment to ...

The Justice Department’s Tax Division has recently announced a major policy shift that will invariably result in longer jail sentences for individuals convicted of failing to report their offshore ...

In Bittner v United States, SCOTUS settled the question of the appropriate method of calculating strict liability penalties for the failure to timely disclose reportable accounts on an FBAR.

The Supreme Court has docketed Bittner v. U.S. for its fall calendar, setting it to resolve a split between the Fifth Circuit and the Ninth Circuit on the penalty for violation of the Report of ...

The Report of Foreign Bank and Financial Account, or FBAR, is an annual informational tax report that must be filed by certain U.S. individuals and legal entities to report their foreign bank accounts ...

Over the past 10 years, this column has detailed the Internal Revenue Service's aggressive pursuit of taxpayers with undisclosed offshore accounts. In addition to criminal prosecutions, the IRS's ...