Willful

July 21, 2020

Texas Woman Sentenced to Serve 33 Months In Federal Prison for Tax Fraud

Texas Woman Sentenced to Serve 33 Months In Federal Prison for Tax Fraud According to a Department of Justice press release, a Honey Grove, Texas woman […]
July 13, 2020

FBAR Non-Willful Penalties are Now “Per-Form,” Not Per-Account

FBAR Non-Willful Penalties are Now “Per-Form,” Not Per-Account Each year, thousands of U.S. taxpayers who hold assets overseas or money in offshore bank or financial accounts […]
February 9, 2017
What Does a Willful Failure to Report Offshore Accounts Really Mean?

What Does a Willful Failure to Report Offshore Accounts Mean?

On this blog, we have frequently discussed the willfulness standard as it relates to one’s duty to satisfy offshore account and asset disclosure obligations set forth […]
February 6, 2017
defendant with lawyer speaking to a judge in the courtroom trial

A Deliberate or Willful Blindness Jury Instruction Is Rarely a Good Sign for a Criminal Tax Defendant

Recently on the Federal Tax Crimes blog, the tax fraud case of Happy Asker was analyzed in the context of the willful blindness jury instruction given […]
January 25, 2016
Swiss Bank Program

Union Bancaire Privée Joins Swiss Bank Program

Although the new year typically brings resolutions that aim to change a past habit or behavior, the Department of Justice has no such desire to change. […]
November 13, 2015
FBAR Penalties

Reduced FBAR Penalties May Be Permitted Through IRS Guidance

Many individuals with undisclosed foreign accounts are justifiably concerned about their failure to comply with the annual obligation to file FBAR (Report of Foreign Bank and […]