How Can The IRS Impose 13 Negligent FBAR Penalties For 1 Year? Ask the federal district court of California, which recently upheld the IRS’ imposition of separate non-willful penalties against 13 foreign accounts disclosed on a single late FBAR return. The court’s decision raises the stakes for taxpayers looking to quietly report their foreign interests…
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IRS Summons For Law Firm's Client Identities Can Be Enforced
According to Law360, the U.S. can enforce an Internal Revenue Service summons for client information from the Taylor Lohmeyer Law Firm because the firm failed to show attorney-client privilege protected the information, a Texas federal court found. The court, in a order, approved a John Doe summons the government sought to obtain the names of…
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Foreign Sub's Guarantee of US Loan Results in Additional Income
According to Law360, the Third Circuit on May 14, 2019 upheld decades-old tax regulations tied to a $377 million dispute involving the affiliate of a commodities trader, ruling that the IRS wasn’t expected to foresee every possible impact of the rules when they were written. In a precedential ruling, a three-judge panel affirmed a U.S.…
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IRS Review of Foreign Reporting Information Results in Another 50% FBAR Penalty Case
A real estate developer willfully failed to report an overseas bank account to the Internal Revenue Service and is responsible for $456,000 in penalties, a Texas federal court found on June 11,2019. Defendant Edward Flume is a U.S. citizen who has lived and worked in Mexico since 1990. A savvy businessman, Flume has successfully parlayed…
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