FBAR Penalties – Remove, Settle – FBAR Tax – Former IRS, Attorneys  – FBAR Tax Experts – FBAR Consultants

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FBAR Penalties, procedures and applications.

The IRS has been delegated authority to assess FBAR civil penalties. There are civil penalties for negligence, pattern of negligence, non-willful, and willful violations. Each case is different and the results vary from cases to case.

IRS penalties are be asserted only to promote compliance with the FBAR reporting and record keeping requirements.

In exercising IRS discretion, tax examiners 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. We hope!

FBAR civil penalties have varying upper limits, but no floor.

The IRS audit 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. You must hope the tax examiner is fair and uses good judgement.

IRS tax 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.

Because FBAR penalties do not have a set amount, IRS has developed penalty mitigation guidelines to assist examiners in the exercise of their discretion in applying these penalties.

The FBAR mitigation guidelines are only intended as an aid for the examiner in determining an appropriate penalty amount.

The  IRS tax examiner must still consider whether a warning letter or a penalty amount that is less than what would be called for under the mitigation guidelines would be more appropriate given the facts and circumstances of a particular case.

FBAR penalties are determined per account, not per unfiled FBAR, for each person required to file.

IRS 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.

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