Foreign Audit FAQ

March 25, 2014

What is the process of an FBAR referral?

Acceptance by the Criminal Investigation Division (CID) of an FBAR referral depends on the strength of the evidence establishing willfulness. To aid in the examination a […]
March 25, 2014

Overview of an administrative criminal investigation

For starters, administrative investigations are categorized as general investigations, primary investigations or subject to criminal investigations based upon the alleged indiscretion and the manner in which […]
March 25, 2014

Is a penalty assessment ripe for judicial review?

The U.S. Tax Court has held that it does not have jurisdiction to review the IRS’s decision to impose an FBAR penalty. In Williams v. Commissioner, […]
March 25, 2014

How might an FBAR audit be resolved?

Closing procedures typically vary depending on the results of the examination. In all cases, the examiner will support the determination in a summary memorandum with references […]