Can I Raise Any Defenses to the FBAR Penalty?
Just because the IRS thinks that an FBAR penalty is warranted does not make it “official.” Indeed, a taxpayer can challenge the assertion. In doing
Just because the IRS thinks that an FBAR penalty is warranted does not make it “official.” Indeed, a taxpayer can challenge the assertion. In doing
For most cases involving multiple nonwillful violations, examiners will recommend one penalty for each open year, regardless of the number of unreported foreign financial accounts. In those
For cases involving willful violations over multiple years, examiners will recommend a penalty for each year for which the FBAR violation was willful. In most cases,
In the same way that the decision to impose a FBAR penalty is discretionary, so too is the decision for what the actual amount of that
To the extent that the examiner attempts to assert a willful FBAR penalty, the burden is on the IRS to show that the violation was, in
The IRS has authority to assert FBAR civil penalties. Before delving any deeper into the FBAR abyss, an important point must be made in order to
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