A recent federal case demonstrates the perils of FBAR litigation and the harsh penalties that apply for a willful failure to file an FBAR (FinCEN Form 114) to report a foreign account. The case involved an IRS civil FBAR penalty assessment of $988,245 for an unreported Canadian financial account. The defendant/taxpayer checked “no” on Schedule B of his federal tax returns …
In 1996, Congress enacted Section 6048.[1] Under that provision, certain persons are responsible for reporting transactions or relationships with foreign trusts on IRS Form 3520 and/or IRS Form 3520-A. The failure to timely file an IRS Form 3520 and/or IRS Form 3520-A can result in significant civil penalties and potential criminal referrals. However, until recently, there has been significant …
The Joint Chiefs of Global Tax Enforcement (known as the “J5”) has been busy the last few months. The group – compromised of tax department heads from Australia, England, Canada, the Netherlands, and the United States – was formed in June 2018 to facilitate the sharing of information regarding international tax cheats. A summary of some of their more recent …
