FBAR Reporting Requirements
Given the renewed focus of the IRS on international tax compliance issues, it should come as no surprise that FBAR indictments and court cases are becoming increasingly prevalent.
Read MoreIRS and Court Decisions
Reviews of court rulings and IRS decisions affecting U.S. expats, especially on FBAR penalties, Form 5471 and the foreign earned income exclusion.
FBAR Reporting Penalties Can Be Severe
A number of recent cases decided around the country show that foreign bank account reporting (FBAR) penalties are no laughing matter and can quickly escalate depending on the circumstances.
Read MoreAccidental Americans Claiming Discrimination
As reported by Reuters, a group of American citizens living in France filed a class-action lawsuit this past week against local financial institutions, alleging discrimination due to their U.S.…
Read MoreWillful FBAR Penalty Limit
When taxpayers are caught late filing the FBAR, the IRS will assess penalties based on whether it thinks the individual’s conduct was willful or non-willful. The difference in penalty regimes are…
Read MoreForeign Earned Income Exclusion Disallowed for Military Contractor
Continuing the trend of recent cases, the Tax Court again disallowed the foreign earned income exclusion (“FEIE”) in the case of a contractor for the U.S. military who worked in Afghanistan during…
Read MorePassport Revocation Rule for Unpaid Taxes
We’ve written previously about the newly-enacted Code Section 7345 of the Internal Revenue Code, which authorizes the denial, revocation, or limiting of a delinquent taxpayer’s U.S. passport. We’ve…
Read MoreHelicopter Pilot in Iraq Wins FEIE Case
In a decision that bucks the recent trend of taxpayer defeats, the Tax Court in Linde v. Commissioner (T.C. Memo 2017-180) ruled against the IRS in allowing a U.S. citizen helicopter pilot working in…
Read MoreCourt Denies Foreign Earned Income Exclusion
Following the trend of the past several years, courts continue to review foreign earned income exclusion cases at a relatively high rate. In most of the recent cases, the courts have denied the FEIE…
Read MoreInternal Revenue Code (IRC) Section 7345
In our blog from back at the end of December of 2015, we discussed a newly-enacted Code Section 7345 of the Internal Revenue Code, which authorizes the denial, revocation, or limiting of a delinquent…
Read MoreTransfer from OVDP to Streamlined Program
In a very recent decision (Maze v. IRS), the D.C. Circuit Court of Appeals upheld a lower court decision blocking several taxpayers’ efforts to leave the OVDP tax amnesty program and enter the…
Read MoreTurbotax Defense Fails Again in Tax Court
As we’ve blogged about previously, self-preparing your tax return can be a risky endeavor, especially for U.S. expats with heightened reporting obligations.
Read MoreFBAR Delinquent Taxpayers
A recent U.S. District Court case has again shone a spotlight on the lack of a clear statutory or regulatory definition of “willful” for purposes of applying the more severe penalties for failure to…
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