The extended deadline for the IRS's voluntary disclosure program to comply with the Report of Foreign Bank and Financial Accounts (FBAR) is approaching. With this deadline nearing, practitioners expect to see increasing litigation concerning whether a failure to file a foreign bank account report with the IRS was willful. Practitioners also expect the IRS to increase it's international enforcement as over $3 billion has been made from the voluntary disclosure program. The full article may be viewed at Tax Analysts.
See Marie Sapirie, "More Litigation on the Horizon for FBAR Penalties," 2011 TNT 222-4 (Nov. 16, 2011).
Posted by Andrew Hodes, Associate Editor, Wealth Strategies Journal.
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