Tag archives: foreign-bank-accounts

RSS feed of foreign-bank-accounts

Definition of "Willful" in Civil Cases

Definition of "Willful" in Civil Cases

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.

Continue reading


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

Continue reading

All rights reserved the-tax-specialist.com 2017