How Will The IRS Assert FBAR penalties?
Although experienced practitioners knew the IRS position, it was formally unknown whether the IRS was asserting willful violation of FBAR penalties totaling 50% per year of the highest aggregate balance of all accounts for the year with high balance, or if they would follow a more draconian approach by asserting a 50% willful violation penalty …
Although experienced practitioners knew the IRS position, it was formally unknown whether the IRS was asserting willful violation of FBAR penalties totaling 50% per year of the highest aggregate balance of all accounts for the year with high balance, or if they would follow a more draconian approach by asserting a 50% willful violation penalty …
Although experienced practitioners knew the IRS position, it was formally unknown whether the IRS was asserting willful violation of FBAR penalties totaling 50% per year of the highest aggregate balance of all accounts for the year with high balance, or if they would follow a more draconian approach by asserting a 50% willful violation penalty …
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Experienced
IRS Tax Attorney
Vic was a Senior Trial Attorney with the IRS Office of Chief Counsel in Laguna where he was recognized by the Department of Treasury for his exemplary service. As a Senior IRS Tax Lawyer, Vic has successfully represented clients on all types of tax issues.
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