New Court Case Limits the Reasonable cause exception to FBAR penalties

- By : P. Patel

Taxpayers across the country rely on advice from their accountants and CPAs to meet the complicated requirements of the U.S. Tax Code. But a new case, Jarnagin v United States, in the U.S. Court of Federal Claims suggests that CPA advice may not be enough to stop the IRS from assessing FBAR penalties for non-willful

The Misunderstood Extension of time to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)

- By : P. Patel

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced an automatic six-month extension for taxpayers required to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR). Taxpayers now have until October 16 to submit their FBARs for 2016 without being subject to penalties. There is no specific FBAR extension document or form

IRS Issues Reminders for FBARs and other International Requirements

- By : P. Patel

The Internal Revenue Service today reminded U.S. citizens and resident aliens, including those with dual citizenship, to check if they have a U.S. tax liability and a filing requirement. At the same time, the agency advised anyone with a foreign bank or financial account that a new deadline now applies to reports for these accounts,

2016 US Dept of Justice (DOJ) Tax Division: FBAR penalty collection cases

- By : P. Patel

The US Dept of Justice (DOJ) Tax Division  recently published it annual summary highlights of civil tax matters. The publication is linked here (Updated through December 16, 2016), and contains brief summaries DOJ Tax activity (decisions, court filings, etc.). Last year it appears that the government enforced collection of FBAR penalties has substantially increased.   Also surprising was

Permanent annual automatic extensions granted for FBARs to October 15

- By : P. Patel

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced last week that, to implement the new due date for FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR), of April 15 (April 18 for 2017), it will automatically grant all taxpayers filing the form a six-month extension every year to Oct. 15 (which

FBAR Reforms Recommended

- By : P. Patel

If you have a financial interest in or signature authority over a foreign financial account, including a bank account, brokerage account, mutual fund, trust, or other type of foreign financial account, exceeding certain thresholds, the Bank Secrecy Act may require you to report the account yearly to the Department of Treasury by electronically filing a

NY Art Consultant Indicted for Filing False Tax Returns and Failing to File FBARs

- By : P. Patel

Last week, on July 28, 2016, the United States Department of Justice announced an indictment against Lacy Doyle for obstructing the administration of tax laws and filing false foreign bank account report (FBARs). Doyle was arrested in New York. In 2003, Ms. Doyle’s father died and left an inheritance of over $4 million to Doyle.

New FBAR Deadlines and Penalty Relief available

- By : P. Patel

The US Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 (the Act) has changed the filing date for the Report of Foreign Bank and Financial Accounts (FBAR), electronically filed with the Financial Crimes Enforcement Center (FinCEN) on Form 114, effective for reports for calendar year 2016 accounts due in 2017. The Act

Delinquent FinCen Form 114 (FBAR) Filings

- By : admin

Time is of the essence when dealing with a delinquent FinCen Form 114 (FBAR). A taxpayer who has not been already contacted by the government should immediately take steps to cure the noncompliance because the IRS has increased enforcement of the reporting of foreign (non-U.S.) financial accounts and their related incomes. Recent media articles surrounding penalty

New FBAR Deadline applies to 2016 Tax Year Onwards

- By : P. Patel

On July 31, 2015, President Obama signed into law P.L. 114-41, which included a number of tax provisions, one of which changes the deadline for filing the Report of Foreign Bank and Financial Accounts (FinCEN Form 114) (the FBAR) for 2016 and future years. The FBAR must be filed by a U.S. person (i.e., an individual