JournalofAccountancy

Eleventh Circuit finds some FBAR penalties are excessive

The Eleventh Circuit held that three penalties of 23 assessed against a taxpayer for failure to file Financial Crimes Enforcement Network (FinCEN) Form 114, Report of Foreign Bank and Financial ...
SlashGear

Woodworking Clamps: A Complete Guide To Each Type (And What They're Used For)

We may receive a commission on purchases made from links. Experienced builders and new arrivals alike might entertain just a bit of curiosity surrounding some of the gear these YouTubers bring out ...
SlashGear

Woodworking Clamps: Which One Is Also Known As A Speed Clamp? (And What Is It Used For?)

We may receive a commission on purchases made from links. Woodworking is a trade or hobby that requires just a few basic tools to get started. Anyone with a saw, a hammer, a few chisels, and a handful ...
JournalofAccountancy

FBAR penalties are not taxes imposed by the Code

The Tax Court held that FBAR penalties are not a tax imposed by the Code and, therefore, are not subject to the requirements of Secs. 6320 and 6330. Facts: Stephen C. and Judy A. Jenner were assessed ...
Forbes

FBAR And The Eighth Amendment: The Mistakes Of Toth

Forbes contributors publish independent expert analyses and insights. Robert Goulder covers developments in U.S. and international taxation. I don’t always agree with the dissenting opinions of ...
JD Supra

FBAR: The Eleventh Circuit Holds That Willful FBAR Penalties are Subject to the Eighth Amendment Creating Circuit Split

For years, FBAR litigants have made the commonsense argument that large willful FBAR penalties, which can exceed the value of the unreported foreign accounts themselves, violate the excessive fines ...
Forbes

How To Distinguish FBAR Willfulness From Non-Willfulness With Examples

U.S. citizens and residents with financial interests in foreign accounts that exceed $10,000 at any time in a year must file an FBAR. The failure to file an FBAR can be costly. If the government shows ...
Seeking Alpha

Broadcom: Broad Runway In Growth Providing Apple With FBAR Chips

Broadcom transformed itself from small player to a market leader through acquisitions and growth. The company dominates BAW filter market (87% share) - crucial for smartphones. The company exhibits ...
JD Supra

FBAR Penalty Defenses and Techniques: The Wrong “Willful” Penalty Computation

On September 8, 2023, the IRS issued a News Release suggesting that FBAR compliance investigations and audits would heat up in the near future. For those unfamiliar with FBARs, federal law requires ...
Electronic Design

The Active Clamp Flyback Converter: A Design Whose Time Has Come

One trend that shows no size of ending is the move to smaller personal electronic devices. From smartphones to tablets, each successive generation is smaller and more powerful than the last. It’s ...
The National Law Review

Non-Willful Failure to File FBAR Under BSA Should Be Penalized on a Per-Report Basis, Supreme Court Rules for Taxpayer Against IRS

We collaborate with the world's leading lawyers to deliver news tailored for you. Sign Up for any (or all) of our 25+ Newsletters. Some states have laws and ethical rules regarding solicitation and ...