In recent years, the government has made concerted efforts to win willful FBAR penalty cases through summary judgment motions. This is not surprising. Thus far, it has convinced courts that ...
As a general matter, the FBAR is not a difficult tax form to prepare, at least for most taxpayers and their tax professionals. At its very basics, it merely asks for identifying information regarding ...
A recent FBAR case—well, kind of—serves as a reminder that FBAR penalties can be [*fill in your pejorative adjective of choice*]. In United States v. Buff, the government initiated a suit to collect ...
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