The Danger of a Quiet Disclosure

The Government’s Warning to Taxpayers: False Certifications of Non-Willfulness Will Be Prosecuted

Recent FBAR Case: Signing and Not Reading Tax Return Leads to $900,000 Penalty

The Panama Papers: The First U.S. Conviction for Tax Fraud

International Reporting Penalties

Where Is the Limit on Penalties for Willful FBAR Violations?

The Recent FBAR Case Allows Multiple Penalties for Single Failure to File FBAR

The Willful FBAR Penalty: Bedrosian and New Insights

FBAR Penalty Update

Another FBAR Penalty Case Demonstrates the Perils of Failing to Report a Foreign Account

The Colliot Decision: The Government Loses an FBAR Case that May Change International Reporting Penalties

The Paradise Papers Continue to Shed Light on the Use of Offshore Tax Havens

IRS Required to Return FBAR “Penalty:” Penalty was “Illegally Exacted”

Non-US Residents May Still Be Subject to FBAR Reporting Guidelines

How the FBAR’s “Willfulness” Element Has Recently Evolved

Former University Professor sentenced to Prison for Hiding over $220 Million in Offshore Accounts—Pays $100 Million to Resolve FBAR Penalties

FinCEN Announces Automatic FBAR Extension

Litigating FBAR Penalties | The Burden of Proof and the Meaning of Willfulness