In a recent case, the Fifth Circuit analyzed whether the $10,000 maximum non-willful FBAR penalty cap applies for each failure to file an annual FBAR or each failure to report an account. In an ...
Under prior law, taxpayers were required to file FinCEN Form 114 (FBAR) on or before June 30 of the year immediately following the calendar year being reported. There was no extension of time to file.
In Boyd, the taxpayer first disclosed her interest in several financial accounts located in the United Kingdom in connection with her participation in the IRS's 2012 Offshore Voluntary Disclosure ...
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