Government Fails to Prove Taxpayer “Willfully” Concealed Offshore Bank Accounts
Under foreign bank account reporting requirements, a U.S. person who has a financial interest in or signature authority over financial accounts in a foreign country where the aggregate value exceeds $10,000 is required to file a Report of Foreign Bank and Financial Accounts (FBAR, Form TD F 90-22.1). The current civil penalty for an inadvertent failure to file an FBAR is $10,000, absent a reasonable cause exception, and the current penalty for a willful failure is the greater of $100,000 or one-half of the account balance.
Defendant J. Bryan Williams did not disclose ownership of two [...]Read more