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 »

Key Estate Planning Concepts for International Clients

Estate Planning International Clients

K&D associate, Patrick J. McCormick, authored the below article, “Key Estate Planning Concepts for International Clients”, which will appear in the forthcoming June 2017 issue of Estate Planning, a nationally recognized journal published by Thomson Reuters, and again in a Summer 2017 issue of the Journal of International Taxation, also published […] 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 »

ALERT: Form BE-10 Required for Clients with Foreign Rental Real Estate By June 30, 2015

In recent years, tax practitioners who have clients with foreign assets have been inundated with information regarding offshore filing requirements.  The vast majority of information publicized focuses on the FBAR filing requirement, with supplementary focus on forms required to be filed with a taxpayer’s Form 1040 (such as Forms 8938 […] 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 »