FBAR

March 20, 2020
What is the Statute of Limitations for the IRS to Assess Tax, and Are There Exceptions for Taxpayers Abroad?

Why the FBAR Statute of Limitations Won’t Save You

The “Limits” of the FBAR Statute of Limitations: Page Contents at a Glance A favorite trope in crime dramas is to save a protagonist from prosecution […]
March 13, 2020
Photo by Doran Erickson on Unsplash

Treasury Excepts Reporting for Interests in Certain Tax-Favored Retirement and Non-Retirement Savings Trusts in Revenue Procedure 2020-17

Last week, the Treasury Department released Revenue Procedure 2020-17, which provided taxpayers guidance regarding information filing requirements related to certain tax-favored foreign retirement trusts and certain […]
February 27, 2020

Another Swiss Bank Admits to Tax Evasion, Putting More U.S. Account Holders at Risk

Under a series of tax laws, intergovernmental agreements (IGAs), and international treaties, such as the Foreign Account Tax Compliance Act (FATCA), offshore banks are obliged to […]
January 26, 2020

Swiss Bank Enters Into Amended Non-Prosecution Agreement With DOJ, Pays Additional $14 Million Fine

According to a Department of Justice press release, Union Bancaire Privée, UBP SA (UBP), a Geneva, Switzerland-based bank recently entered into an amended non-prosecution agreement with […]
November 26, 2019

IRS LB&I Announces Post OVDP Compliance Campaign, Signaling Danger for International Taxpayers

The IRS Large Business and International Division, better known as “LB&I,” is the branch of the IRS focused on taxpayers with significant assets, such as partnerships […]
November 19, 2019

Court Upholds $800,000 FBAR Penalty Against Woman Who Concealed Swiss Bank Account

Our tax law blog offers numerous cautionary tales of taxpayers who received hefty penalties after failing to report foreign bank accounts, such as the banker fined […]