There has been a potentially landscape-altering decision out of the Fifth Circuit Court of Appeals (Court) regarding Reports of Foreign Bank and Financial Account (FBAR) penalties. In United States v. Bittner, that Court has held that each failure to report a qualifying account is a separate violation. This is a significant split from the Ninth [...]
[vc_row][vc_column][vc_column_text] Taxpayers often wonder how they might be selected for audit by the Internal Revenue Service (IRS). Often, audit selection is random. However, the IRS also runs certain “compliance campaigns” related to areas in which the IRS detects a significant increase in abuse by taxpayers or their advisors. Changes in bank secrecy laws of foreign [...]