Willfulness

Cross-Border Tax Insights, FBAR, International Tax, Willfulness

IRS Goes After Holocaust Survivor for Willful FBAR Penalty

By Jason B. Freeman Mar 13, 2022
Criminal, White-Collar Defense Insights, Willfulness

Willful Blindness and Corporate Liability

By Jason B. Freeman Jul 29, 2020
Bank Secrecy Act, FBAR, International Tax, Penalties, Willfulness

FBAR Penalty Update

By Jason B. Freeman Oct 24, 2018
Popular Posts, Willfulness

Not So Fast, IRS…My Client Wasn’t Aware: Marinello v. United States

By Freeman Law Mar 26, 2018
Bank Secrecy Act, FBAR, White-Collar Defense Insights, Willfulness

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

By Jason B. Freeman Sep 22, 2017
Criminal, Willfulness

Department of Justice Issues Warning on the Eve of Tax Deadline: Willful Tax Violators Face Prosecution

By Jason B. Freeman Apr 18, 2017
Cross-Border Tax Insights, FBAR, White-Collar Defense Insights, Willfulness

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

By Freeman Law Apr 07, 2017
Bank Secrecy Act, Cross-Border Tax Insights, FBAR, Fraud, International Tax, Offshore Tax, OVDP, Willfulness

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

By Jason B. Freeman Feb 24, 2017
Bank Secrecy Act, Defenses, FBAR, Tax Litigation Insights, White-Collar Defense Insights, Willfulness

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

By Jason B. Freeman Dec 16, 2016
Criminal, Employment Tax, Willfulness

The Crime of Willfully Failing to Collect or Pay Over Tax

By Jason B. Freeman Sep 28, 2016
Bank Secrecy Act, FBAR, White-Collar Defense Insights, Willfulness

Foreign Bank Account Reporting | The FBAR

By Freeman Law Sep 09, 2016
Criminal, Defenses, White-Collar Defense Insights, Willfulness

The Cheek Defense to Federal Tax Crimes

By Freeman Law Aug 19, 2016