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Should you have a financial interest in or signature authority over a foreign financial account, including a bank account, brokerage account, mutual fund, trust, or other type of foreign financial account, the Bank Secrecy Act may require you to report the account yearly to the Internal Revenue Service by filing Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR). You can find this form on our website. Go to the homepage and look for the toolbar that reads IRS Forms.
The FBAR is required because foreign financial institutions may not be subject to the same reporting requirements as domestic financial institutions.
The FBAR is a huge tool to help the United States government identify persons who may be using foreign financial accounts to circumvent United States law. Investigators use FBARs to help identify or trace funds used for illicit purposes or to identify unreported income maintained or generated abroad. In recent years it has tracked terrorism suspects and drug activity. The IRS has team of tax auditor and criminal investigators that are tax specialist to trace down tax cheats and evaders.
33,000 FBAR filers came forward the first 3 years of the program and the IRS collected over $5 Billion. This project is priority number one because of the volume of revenue the FBAR brings in. Also the fear of criminal prosecution makes these cases easy to work because of the leverage the government can use. IRS publishes a list of all those convicted of FBAR violations on their website.These violators are given prison time and huge tax fines.
The FBAR must be received by the Department of the Treasury on or before June 30th of the year immediately following the calendar year being reported.
The June 30th filing date may not be extended.
There are civil and criminal penalties for negligence, pattern of negligence, non-willful, and willful violations.
Penalties for FBAR may be abated and varies from case to case. You can call us today to see how you can qualify. Many FBAR violators were simply unaware of the requirement and in many cases IRS has been forgiving in abating penalties and interest. Penalty abatement’s are done on a case by case basis, no two cases are the same.
Whenever there is an FBAR violation, the examiner will either issue the FBAR warning letter, Letter 3800, or determine a penalty.
The tax examiner (IRS tax auditor ) in exercising their discretion will consider whether the issuance of a warning letter and the securing of delinquent FBARs, rather than the assertion of a penalty, will achieve the desired result of improving compliance in the future. Common sense should be the play of the day however that is not always the case.
FBAR civil penalties have varying upper limits, but no floor.
The tax examiner has discretion in determining the amount of the tax penalty. The tax examiner discretion is necessary because the total amount of penalties that can be applied under the statute can greatly exceed an amount that would be appropriate in view of the violation.
FBAR penalties are determined per account, not per unfiled FBAR, for each person required to file.
FBAR penalties apply for each year of each violation. As noted above, however, examiners are expected to exercise discretion, taking into account the facts and circumstances of each case, in determining whether penalties should be asserted and the total amount of penalties to be asserted. The auditor has tremendous power and authority in making these decisions.
There can and may be multiple FBAR civil penalty assessments arising from one account.Many times this is the case. These however truly vary from case to case. That is where the help from a former IRS Agent comes in hand, we know the guidelines.
FBAR civil penalties can apply to each person with a financial interest in, or signature or other authority over, the foreign financial account.
Thus there may be multiple penalty assessments if there is more than one account owner or if a person other than the account owner has signature or other authority over the foreign account. Each person can be liable for the full amount of the penalty. Our tax attorneys and tax lawyers have handled a plethora of cases and know all the criteria for penalty abatement.
If you are looking for true tax experts call us today for a no cost professional tax consultation and speak directly to a Tax Attorney, Tax Lawyer or Former IRS agent.
Call us at 1-866-700-1040.