Jeremy H. Temkin Non-Willful FBAR Penalties: A (Temporary) Reprieve for Taxpayers?
The IRS is authorized to impose a penalty of up to $10,000 for "any [non-willful] violation" of FBAR provisions. In recent years, district courts have disagreed regarding whether this provision authorized a separate penalty for each undisclosed account or limited the IRS to a single $10,000 penalty, regardless of the number of accounts at issue. In late March, the Ninth Circuit became the first Circuit Court of Appeals to address this issue. In this edition of his Tax Litigation Issues column, Jeremy H. Temkin discusses the opinion, which provides a useful roadmap for practitioners representing taxpayers.
May 19, 2021 at 12:45 PM
8 minute read
For over a dozen years, the Internal Revenue Service and the Department of Justice have targeted the use of offshore accounts to evade U.S. income taxes. In testimony before Congress last month, IRS Commissioner Charles P. Rettig made it clear that this crackdown on offshore tax evasion will continue unabated.
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