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The Bedrosian FBAR case: Another Victory

A recent case in the Third Circuit, Arthur Bedrosian v. United States of America, resulted in a huge win for the taxpayer. Yet it was another loss, after Pomerantz and Hom, for the government, which the court ruled failed to meet the burden for proving a willful FBAR penalty violation. After the entire findings of fact and conclusions of law follows this analysis.

Can you amend FBARs?

Yes. It is possible to amend FBAR forms. But should you? Or should you get an expert to file it for you?

Can you beat the 63% average score? Take the FBAR knowledge challenge

The consequences of filing an incorrect FBAR can be very severe. Before you file your FBAR, ask yourself, how well do you know the intricacies of the law? Take the IRSMedic FBAR challenge quiz now.

Willful "Blindness" and Willful FBAR Penalties

It is nearly impossible to prove willfulness. The IRS, though, has a trick. It only need to prove willful blindness. The "willful blindness" state of mind argued by the IRS is so broad it could be applied to anyone who has not filed an FBAR. 

FBAR penalties and bankruptcy

FBAR penalties can be massive. Willful penalties can be as high as 50% of the account value. A question that many people facing this financial threat ask is "are FBAR penalties dischargable in Chapter 7 ...

Understanding the IRS OVDP Offshore Penalty

The current 2012 Offshore Voluntary Disclosure Program presents taxpayers faced with a potentially high IRS offshore penalty (up to 50% of foreign account value per year, for unfiled FBARs) the chance to disclose their foreign assets voluntarily and accept an IRS Offshore Penalty of 27.5%, ...

What is a foreign bank account?

Thanks to the Bank Secrecy Act of 1970, U.S. citizens must file a "Report of Foreign Bank and Financial Accounts" if they have a financial interest in, or authority over, "foreign bank accounts" or "foreign financial accounts" that have an aggregate value of ...

FBAR Penalty Guide

When people hear that FBAR penalties could potentially be up to 50% of your account balance, they rightfully get upset. The world of FBAR penalties is a large, complicated one. We've created this FBAR Penalty guide to help you muddle through.

September 2015 FBAR Webinar

This webinar is about FBAR help for those who are not in an FBAR Amnesty Program. What is going to happen now? And again our assumption here is that you’re not in an FBAR Amnesty Program aka sort of Offshore Voluntary Disclosure ...

September 2015 OVDP Webinar

Thanks to all who joined us on our live OVDP Webinar on September 11th.  It was a great success -  be sure to check back in for additional live webinars as they come back in. Below is the webinar as well as the transcript.

Feeling lucky? Take a gamble on IRS Forms 11-C and 730

Recently I found myself taking a look at the taxation of gambling. But, just so we're all on the same page, I'm not talking about income tax due from gambling. Instead, we're focusing on the excise taxes imposed on gambling, which include... illegal gambling!

FBARs and the Fifth Amendment

Would you believe that the Fifth Amendment's right against self-incrimination stems from some rather intense church - state intermingling? Not only that but a church - state mingling so intense that it's one of the primary reasons the United States ...

FBAR Penalty Appeals Process

Thanks to all the recent commotion about offshore financial accounts and banks being forced to provide evidence against their account holders, one thing is becoming painstakingly clear to the taxpaying public - the IRS is out for blood. The IRS's new - found focus on foreign and ...

FBAR Penalty Procedures

The IRS announced a rather significant update to FBAR Penalty assessment procedures on May 13, 2015. These procedures are what are to be followed during an FBAR audit whether inside or outside an Opt - out audit. For the most part, this will make the FBAR penalties lower ...

What is the FBAR penalty statute of limitations on collections?

For typical IRS tax debts, the statute of limitations on collections is 10 years. In IRS-speak this "statute of limitations" is called the Collection Statute Expiration Date or CSED (pronounced "SEE-said"). And wouldn't you know it, if you have been assessed an FBAR Penalty (or several) during an FBAR or Opt-Out audit there is an FBAR CSED as well. There is a statute of limitations on collecting FBAR penalties, but ...

IRS FBAR late filing help

You may have just learned that the IRS has a problem with your offshore bank accounts.  If so, here are two critical facts to be aware of: 1) You are not alone. 2) You (probably) did nothing “wrong.” Hundreds of thousands of US taxpayers have failed to ...

What is the IRS collection process?

Whether you have just learned that you owe money to the IRS, or have had a lingering tax problem for many years, in this article we will explain the three phases of the IRS collection process.

OVDI/OVDP Opt-out: Results And Updates

Many of our past, present, and likely future clients wait to see how the state of OVDI/OVDP opt-out shapes up in coming months and years. This opt-out option, unavailable during the original 2009 program, was first implemented in 2011 and almost all of our ...

FBAR Penalties: Likely consequences for not filing

Let's just this out of the way, we aren't going to be talking about jail. The reason is that for most FBAR non - filers, going to jail for failing to file an FBAR is highly unlikely. The point of this article to to discuss the likely consequences for not ...

FBAR Penalty Procedures

What are the FBAR penalty procedures administrative processes? An IRS examiner will determine, based on facts and circumstances (and IRM guidelines) what action is appropriate in the FBAR case. If FBAR penalty procedures are found...

OVDI/OVDP Opt-Out FAQ: Your Top Questions Answered

Since the "opt-out" process was first introduced in the 2011 Offshore Voluntary Disclosure Initiative (OVDP/OVDI), we have helped countless US taxpayers and tax professional understand one of the most confusing aspects of the current OVDP, "the opt-out." Here is our OVDI/OVDP Opt-Out ...

5 things to know about FBAR penalty negotiations

As you probably know, the IRS has a new focus on FBAR penalty enforcement. This makes FBAR Penalty negotiation extremely important. Because of the strange history of the form and the Bank Secrecy Act, many people can't quite figure out what all of this means. In order to help you understand the ...

OVDP Payment Plans: Getting An Option You Can Live With

For many US taxpayers considering whether or not to enter in to the IRS Offshore Voluntary Disclosure Initiative/Program (OVDI/OVDP), one of the biggest concerns is, "What if I am forced to accept a 27.5% FBAR - equivalent offshore penalty? What if I am stuck with a bill that I can't"...

Dual Passport? The IRS Can Still Find Your Foreign Accounts!

Since the 2012 Offshore Voluntary Disclosure rules were passed, my office has spoken to hundreds of US persons who have undisclosed offshore accounts. Many have decided to use our services, some have decided to hire our OVDI attorney peers, and many have decided to roll the dice, because of a ...

OVDP Opt-out Appeals

UPDATE 2016: OVDP opt-out appeals are indeed handled by the highest level of IRS appeals officers. Their goal is to see that the law is applied consistently and that they take into account the risks of litigation. For more recent information,...

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IRS Medic: Parent & Parent, LLP
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