“It remains uncertain whether the IRS would or could effectively pursue those residing outside the United States in any realistic manner.” “Could the government actually carry their burden of demonstrating that the taxpayer “willfully” violated the FBAR filing requirements?” … U.S. taxpayers residing in the United States having previously undisclosed interests in foreign financial accounts […]
IRS FBAR Voluntary Disclosure Program vs Quiet Disclosure
02/04/2016
