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 …