FBAR – Wagner Tax Law

Split In The 5th Circuit Muddies The FBAR Waters

There has been a potentially landscape-altering decision out of the Fifth Circuit Court of Appeals (...

May 13, 2020Ben WagnerCategories: Ben Wagner, FBARTags: california tax attorney, California tax lawyer, death and taxes, disclosure FBAR, FBAR, FBAR controversey, FBAR disclosure, FBAR dispute, FBAR penalties, FBAR program, Form 433-A FBAR, Form 433-B FBAR, Form-B FBAR, increase FBAR, inflation FBAR, IRS attorney twin cities, irs audit settlement, irs audit tax attorney, IRS Audits, irs california audit, irs examination, irs fbar, IRS information, IRS tax attorney, irs tax lawyer, Minneapolis Tax Attorney, Minneapolis Tax Firm, Minneapolis Tax Lawyer, Minnesota Department of Revenue, Minnesota Department of Revenue audits, Minnesota Tax Firm, mn audit settlement, MN Tax Attorney, MN Tax Firm, MN Tax Lawyer, OVD Program, quiet disclosure FBAR, quiet FBAR, Report of Foreign Bank and Financial Account (FBAR), tax attorney saint paul, tax lawyer saint paul, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer, wisconsin irs issues, wisconsin tax attorney, wisconsin tax lawyer

Death Is No Defense When It Comes To FBAR Penalties

People often joke that the only certainties in life are death and taxes. Well, it turns out that, wh...

September 18, 2018Ben WagnerCategories: FBARTags: 2011 OVD Program, 2012 OVD Program, california tax attorney, California tax lawyer, chicago tax attorney, chicago tax lawyer, FBAR, FBAR controversey, FBAR disclosure, FBAR dispute, FBAR program, Foreign Bank Account Reporting, Internal Revenue Service, Internal Revenue Service’s (IRS’s) Offshore Voluntary Disclosure Program (OVD Program), IRS', Isle of Mann Tax Treaty, Metro MN Tax Lawyer, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, minnesota tax, MN Tax Attorney, Offshore Voluntary Disclosure Program (OVD Program), OVD Program, Report of Foreign Bank and Financial Account, Report of Foreign Bank and Financial Account (FBAR), san francisco tax lawyer, sanfrancisco tax attorney, st. paul tax, st. paul tax attorney, st. paul tax lawyer, States of Guernsey Tax Treaty, States of Jersey Tax Treaty, tax attorney mn, tax lawyer mn, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer, wi tax attorney, wisconsin tax attorney

The IRS’s Expanding Definition Of Willfulness In FBAR Cases

The Internal Revenue Service’s (IRS’s) Offshore Voluntary Disclosure Program (Program) has eleme...

April 3, 2018Kathleen (Splett) PfutzenreuterCategories: Accounting, Appeals, Audits, Ben Wagner, Collection Issues, Collection Options, FBAR, Kathleen (Splett) Pfutzenreuter, Levy, Offshore Voluntary Disclosure Program, Penalties, UncategorizedTags: 2011 OVD Program, 2012 OVD Program, civil penalties offshore voluntary disclosure program, civil penalties OVDP, criminal penalties internal revenue service, criminal penalties IRS, criminal penalties offshore voluntary disclosure program, criminal penalties OVDP, end date OVDP, FBAR, FBAR controversey, FBAR disclosure, FBAR dispute, FBAR penalties, FBAR program, federal tax, federal tax attorney, federal tax lawyer, foreign assets, Foreign Bank Account Reporting, foreign bank accounts, increase FBAR, inflation FBAR, Internal Revenue Service, IRS attorney, irs lawyer, IRS tax attorney, irs tax lawyer, IRS', Metro MN Tax Lawyer, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, minnesota tax, MN Tax Attorney, offshore volunary disclosure, offshore voluntary disclosure program ends, OVDP, penalties assets abroad, penalties foreign assets, penalties foreign bank accounts, penalties money abroad, requirements for offshore voluntary disclosure, requirements for OVDP, st. paul tax, st. paul tax attorney, tax attorney, Twin Cities Tax Attorney

Recent Announcements: The IRS to End Offshore Voluntary Disclosure Program on September 28, 2018; FinCEN Increases FBAR Penalties to Reflect Inflation

Offshore Voluntary Disclosure Program Ends September 28, 2018 The IRS recently announced that it wil...

May 6, 2014Ben WagnerCategories: Ben Wagner, FBARTags: 2011 OVD Program, 2012 OVD Program, Collection Information Statement for Businesses, Collection Information Statement for Wage Earners and Self-Employed Individuals, disclosure FBAR, FBAR, FBAR controversey, FBAR disclosure, FBAR dispute, FBAR penalties, FBAR program, foreign bank account, Foreign Bank Account Reporting, Form 3520, Form 3520-A, Form 433-A, Form 433-A FBAR, Form 433-B, Form 433-B FBAR, Form 5471, Form 5472, Form 8865, Form 926, Form-B FBAR, how to report a foreign bank account, Internal Revenue Service’s (IRS’s) Offshore Voluntary Disclosure Program (OVD Program), Isle of Mann Tax Treaty, Metro Minnesota Tax Attorney, Metro MN Tax Attorney, Metro MN Tax Lawyer, Minneapolis IRS Tax Audit, Minneapolis Tax Attorney, Minneapolis Tax Firm, Minneapolis Tax Lawyer, Minnesota IRS Audit, Minnesota Tax Appeal, Minnesota Tax Attorney, Minnesota Tax Audit, Minnesota Tax Firm, Minnesota Tax Lawyer, MN Tax Attorney, MN Tax Firm, MN Tax Lawyer, Offshore Voluntary Disclosure Program (OVD Program), OVD Program, Quiet Disclosure, quiet disclosure FBAR, quiet FBAR, report a foreign bank account, Report of Foreign Bank and Financial Account, Report of Foreign Bank and Financial Account (FBAR), reporting a bank account abroad, States of Guernsey Tax Treaty, States of Jersey Tax Treaty, Twin Cities, Twin Cities Tax Attorney, Twin Cities Tax Lawyer

Explaining the Basics of the Quiet Disclosure of an FBAR

This is the sixth article in the Offshore Voluntary Disclosure Program (OVDP) Frequently Asked Quest...

April 17, 2014Ben WagnerCategories: Ben Wagner, FBARTags: 2011 OVD Program, 2012 OVD Program, Collection Information Statement for Businesses, Collection Information Statement for Wage Earners and Self-Employed Individuals, FBAR, FBAR controversey, FBAR disclosure, FBAR dispute, FBAR penalties, FBAR program, foreign bank account, Foreign Bank Account Reporting, Form 3520, Form 3520-A, Form 433-A, Form 433-A FBAR, Form 433-B, Form 433-B FBAR, Form 5471, Form 5472, Form 8865, Form 926, Form-B FBAR, how to report a foreign bank account, Internal Revenue Service’s (IRS’s) Offshore Voluntary Disclosure Program (OVD Program), Isle of Mann Tax Treaty, Metro Minnesota Tax Attorney, Metro MN Tax Attorney, Metro MN Tax Lawyer, Minneapolis IRS Tax Audit, Minneapolis Tax Attorney, Minneapolis Tax Firm, Minneapolis Tax Lawyer, Minnesota IRS Audit, Minnesota Tax Appeal, Minnesota Tax Attorney, Minnesota Tax Audit, Minnesota Tax Firm, Minnesota Tax Lawyer, MN Tax Attorney, MN Tax Firm, MN Tax Lawyer, Offshore Voluntary Disclosure Program (OVD Program), OVD Program, report a foreign bank account, Report of Foreign Bank and Financial Account, Report of Foreign Bank and Financial Account (FBAR), reporting a bank account abroad, States of Guernsey Tax Treaty, States of Jersey Tax Treaty, Twin Cities, Twin Cities Tax Attorney, Twin Cities Tax Lawyer

Explaining the Internal Revenue Service’s FBAR Penalty Structure

This is the fifth article in the Offshore Voluntary Disclosure Program (OVDP) Frequently Asked Quest...

March 28, 2014Ben WagnerCategories: FBARTags: 2011 OVD Program, 2012 OVD Program, Collection Information Statement for Businesses, Collection Information Statement for Wage Earners and Self-Employed Individuals, FBAR, FBAR controversey, FBAR disclosure, FBAR dispute, FBAR penalties, FBAR program, foreign bank account, Foreign Bank Account Reporting, Form 3520, Form 3520-A, Form 433-A, Form 433-A FBAR, Form 433-B, Form 433-B FBAR, Form 5471, Form 5472, Form 8865, Form 926, Form-B FBAR, how to report a foreign bank account, Internal Revenue Service’s (IRS’s) Offshore Voluntary Disclosure Program (OVD Program), Isle of Mann Tax Treaty, Metro Minnesota Tax Attorney, Metro MN Tax Attorney, Metro MN Tax Lawyer, Minneapolis IRS Tax Audit, Minneapolis Tax Attorney, Minneapolis Tax Firm, Minneapolis Tax Lawyer, Minnesota IRS Audit, Minnesota Tax Appeal, Minnesota Tax Attorney, Minnesota Tax Audit, Minnesota Tax Firm, Minnesota Tax Lawyer, MN Tax Attorney, MN Tax Firm, MN Tax Lawyer, Offshore Voluntary Disclosure Program (OVD Program), OVD Program, report a foreign bank account, Report of Foreign Bank and Financial Account, Report of Foreign Bank and Financial Account (FBAR), reporting a bank account abroad, States of Guernsey Tax Treaty, States of Jersey Tax Treaty, Twin Cities, Twin Cities Tax Attorney, Twin Cities Tax Lawyer

Explaining the Internal Revenue Service’s FBAR Penalty Structure

This is the fourth article in the Offshore Voluntary Disclosure Program (OVDP) Frequently Asked Ques...

March 7, 2014Ben WagnerCategories: FBARTags: 2011 OVD Program, 2012 OVD Program, Collection Information Statement for Businesses, Collection Information Statement for Wage Earners and Self-Employed Individuals, FBAR, FBAR controversey, FBAR disclosure, FBAR dispute, FBAR penalties, FBAR program, foreign bank account, Foreign Bank Account Reporting, Form 3520, Form 3520-A, Form 433-A, Form 433-A FBAR, Form 433-B, Form 433-B FBAR, Form 5471, Form 5472, Form 8865, Form 926, Form-B FBAR, how to report a foreign bank account, Internal Revenue Service’s (IRS’s) Offshore Voluntary Disclosure Program (OVD Program), Isle of Mann Tax Treaty, Offshore Voluntary Disclosure Program (OVD Program), OVD Program, report a foreign bank account, Report of Foreign Bank and Financial Account, Report of Foreign Bank and Financial Account (FBAR), reporting a bank account abroad, States of Guernsey Tax Treaty, States of Jersey Tax Treaty

Understanding the Basics of the IRS’s Offshore Voluntary Disclosure Program

This is the third article in a series regarding Frequently Asked Tax Questions relating to the Inter...

February 15, 2014Ben WagnerCategories: FBARTags: 2011 OVD Program, 2012 OVD Program, Collection Information Statement for Businesses, Collection Information Statement for Wage Earners and Self-Employed Individuals, FBAR, FBAR controversey, FBAR disclosure, FBAR dispute, FBAR penalties, FBAR program, foreign bank account, Foreign Bank Account Reporting, Form 433-A, Form 433-A FBAR, Form 433-B, Form 433-B FBAR, Form-B FBAR, how to report a foreign bank account, Internal Revenue Service’s (IRS’s) Offshore Voluntary Disclosure Program (OVD Program), Isle of Mann Tax Treaty, Offshore Voluntary Disclosure Program (OVD Program), OVD Program, report a foreign bank account, Report of Foreign Bank and Financial Account, Report of Foreign Bank and Financial Account (FBAR), reporting a bank account abroad, States of Guernsey Tax Treaty, States of Jersey Tax Treaty

Understanding the Basics of the IRS’s Offshore Voluntary Disclosure Program

This is the second article in a series regarding Frequently Asked Tax Questions relating to the Inte...

January 22, 2014Ben WagnerCategories: FBARTags: 2011 OVD Program, 2012 OVD Program, FBAR, FBAR controversey, FBAR disclosure, FBAR dispute, FBAR penalties, FBAR program, Internal Revenue Service’s (IRS’s) Offshore Voluntary Disclosure Program (OVD Program), Isle of Mann Tax Treaty, Offshore Voluntary Disclosure Program (OVD Program), OVD Program, Report of Foreign Bank and Financial Account, Report of Foreign Bank and Financial Account (FBAR), States of Guernsey Tax Treaty, States of Jersey Tax Treaty

Understanding the Basics of the IRS’s Offshore Voluntary Disclosure Program

This is the first article in a series regarding Frequently Asked Tax Questions relating to the Inter...

August 21, 2012Ben WagnerCategories: Audits, FBARTags: Bank Secrecy Act, FBAR, Foreign accounts with an aggregate value of more than $10000, Foreign Bank Account Reporting, IRC 7701

A Primer In Foreign Bank Account Reporting

In 1970, Congress passed the Bank Secrecy Act. The purpose of that Act was to combat money launderin...