News & Analysis as of July 24, 2025

FinCEN › Tax Penalties

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The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -

Willful FBAR Penalties and the Excessive Fines Clause: District Court Says Context is Key

Freeman Law on 3/24/2025

In its recent decision in United States v. Leeds, the United States District Court for the District of Idaho upheld the application of willful penalties against a deceased husband for failing to report certain foreign bank...more

What is Willful Blindness According to the IRS?

Allen Barron, Inc. on 11/27/2024

What is willful blindness according to the IRS? How is this important in tax cases involving unreported or under-reported income, disclosure of offshore assets and income, FinCEN Form 114 (more commonly referred to as an...more

The Statute of Limitations for an IRS Audit

Allen Barron, Inc. on 9/25/2024

What is the statute of limitations for an IRS audit? What rules extend the window for an IRS audit? How long does the IRS usually have to complete an audit of your taxes? Everyone may have a little fear in the back of...more

Federal Courts Weigh in on the FBAR: Providing Relief from Outrageous Penalties

Davies Ward Phillips & Vineberg LLP on 3/23/2023

In this bulletin, we highlight two recent federal court cases in which U.S. taxpayers won major victories against the United States with respect to their obligations to report non-U.S. accounts on FinCEN Form 114 – Report of...more

What Should I Do if I Missed the FBAR Filing Deadline?

Freeman Law on 9/27/2022

Missing any deadline is stressful. But missing a tax deadline is more so. Per the Bank Secrecy Act (Title 31 of the U.S. Code), certain taxpayers must file so-called FBARs (currently FinCEN Form 114) with the government...more

The FBAR (Report of Foreign Bank and Financial Accounts): Everything You Need to Know

Freeman Law on 10/21/2020

What is the Report of Foreign Bank and Financial Accounts (FBAR)? Congress enacted the statutory basis for the requirement to report foreign bank and financial accounts in 1970 as part of the “Currency and Foreign...more

FBAR Penalties: Is it per Account or per Violation?

Foodman CPAs & Advisors on 2/7/2020

U.S. Taxpayers (includes a citizen, permanent resident, corporation, partnership, limited liability company, trust and estate) are required to file a Report of Foreign Bank and Financial Accounts (FBAR) if they have...more

What are some of the monetary penalties and other consequences of failing to properly report my foreign real estate and other...

Rosenberg Martin Greenberg LLP on 3/21/2019

Depending upon how foreign real estate is owned and/or controlled, a number of different tax reporting regimes may be implicated. Each of these has its own corresponding penalties and generally applies to United States...more

2014 Foreign Financial Account Reporting Requirements

Akerman LLP on 6/5/2015

U.S. citizens or residents who owned, directly or indirectly through an entity, beneficially or who had power of attorney/signature authority over one or more foreign financial accounts with an aggregate value exceeding...more

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FinCEN › Tax Penalties

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