Tag archives: foreign-bank-accounts

District Court finds in FBAR penalty trial that the definition of willful in civil cases includes reckless disregard of tax laws. The Court found that the burden of proof in a civil FBAR penalty case was a mere preponderance of the evidence. The IRS was not bound by the opinion of General Counsel or its own manual that state that the definition of willful should be the same in civil cases as in criminal cases.

The Offshore Voluntary Disclosure Program continues to be offered by the IRS to encourage taxpayers who have failed to accurately report funds held in foreign bank accounts and income derived abroad to make full disclosure and avoid potential criminal sanctions