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 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 ...

A Florida jury handed the estate of a Texaco heiress, Lavern N. Gaynor, an $18 million Valentine’s Day boon by deciding that her failure to timely file report of foreign bank and financial accounts ...

Delinquent FBAR Filings: If you have no unreported income and are not under an IRS audit or criminal tax investigation, you may submit delinquent FBARs (FinCEN Form 114) along with a brief explanation ...

A request for public comment reveals the IRS is considering updates to the Voluntary Disclosure practice. The agency states its “commitment to improve its processes, and to further incentivize ...

The FBAR is an annual disclosure of overseas financial holdings mandated under the Bank Secrecy Act (BSA). It aims to prevent money laundering, terrorist financing, and tax evasion by requiring a ...