Tag Archives: FBAR

IRS to Launch FATCA Compliance Campaign for FFIs

Last week, the Acting Director of IRS of Field Operations for the LB&I Foreign Payments Practice (“FPP”) announced that the IRS will launch a compliance campaign this summer focused on foreign financial institutions (“FFIs”) that are not satisfying their reporting obligations under the Foreign Account Tax Compliance Act (“FATCA”).  Speaking at a tax controversy forum … Continue Reading

Two New LB&I Compliance Campaigns Focus on Reporting

For the last several years, LB&I has maintained compliance campaigns to address and improve various areas of tax compliance.  On April 16, 2019, LB&I announced the addition of three new compliance campaigns, two of which involve reporting issues: the Offshore Private Banking Campaign and the Loose Filed Forms 5471 Campaign. Offshore Private Banking Campaign The … Continue Reading

Garrity Ruling is Latest in Growing Debate over Civil Penalties for FBAR Violations

The U.S. District Court for the District of Connecticut has joined a growing debate among lower courts regarding the appropriate civil penalty applicable to willful FBAR violations through its ruling in United States v. Garrity.  The FBAR statute, regulations, instructions, and related guidance require that taxpayers annually report to the Treasury Department any financial interest … Continue Reading
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