FBAR Penalty Assessment and Enforcement


  K&D associate, Patrick J. McCormick, authored the below article, “FBAR Penalty Assessment and Enforcement“. This article, published here with permission, will appear in the July 2017 issue of the Journal of International Taxation (Thomson Reuters/Checkpoint). Mr. McCormick specializes in the areas of international tax and tax compliance.   Introduction […] Read more »

FATCA and the New Frontier in Offshore Reporting Enforcement

* This article originally appeared in the October 2015 issue of Practical Tax Strategies, published by Thomson Reuters. Checkpoint Contents, Federal Library, Federal Editorial Materials, WG&L Journals, Practical Tax Strategies/Taxation for Accountants (WG&L) Practical Tax Strategies, 2015, Volume 95, Number 04, October 2015, Articles, FATCA AND THE NEW FRONTIER IN OFFSHORE REPORTING ENFORCEMENT, Practical Tax Strategies, Oct 2015 […] Read more »

IRS Clarifies FBAR Penalty Assessment Amounts & Criteria for Agents

On May 13, 2015, the Internal Revenue Service issued SBSE-04-0515-0025, titled “Interim Guidance for Report of Foreign Bank and Financial Accounts (FBAR) Penalties.”  The issuance provides limitations for assessment of FBAR penalties under the vast majority of circumstances presented by taxpayers.  The issuance provides both clarity as to worst-case scenarios […] Read more »

Powers of Attorney & IRS FBAR Reference Guide

FBAR Filing and Powers of Attorney: The recently published “IRS Reference Guide on the Report of Foreign Bank and Financial Accounts (FBAR)” explains the purpose of the FBAR, who must file, and provides a host of definitions relating to the FBAR regulations. Perhaps most notably, the reference guide explains that […] Read more »