On July 30, 2014, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) proposed rules requiring U.S. financial institutions to collect “Customer Due Diligence” information. The
To fully understanding your legal duty with respect to disclosing a foreign account on an FBAR, it is first necessary to understand the instructions promulgated
The issue that this blog seeks to address is whether a non-willful taxpayer with an undisclosed offshore account can use the streamlined compliance procedures to
Unlike FBAR penalties that can be asserted for multiple years (up to six under the six-year statute of limitations for FBARs), the offshore penalty is
The IRS has authority to assert FBAR civil penalties. Contrary to popular belief, an FBAR violation doesn’t automatically mean that a penalty will be asserted.
Taxpayers who are considering applying to the OVDP should be mindful of a certain upcoming deadline: August 3, 2014. Willful non-disclosers who do not apply
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