Willful FBAR, Civil Tax Fraud & Tax Evasion Cross Over (Golding & Golding)
Автор: Golding & Golding. Offshore Tax. Board-Certified
Загружено: 2022-01-23
Просмотров: 231
Описание:
https://www.goldinglawyers.com
How Tax Evasion and Willful FBAR are Intertwined
Technically, the FBAR (Foreign Bank and Financial Account Reporting aka FinCEN Form 114) is not a tax form, and therefore there is no tax implication for not filing the form. In fact, the FBAR is not even covered under Title 26 (Internal Revenue Code, the Tax Code) but rather Title 31 (Money & Finance). Thus, despite the fact that a person may not have any tax requirement as a result of having certain foreign bank and other financial accounts abroad, oftentimes a willful failure to report foreign accounts may coincide with the crime of tax evasion. It is not uncommon for a US Taxpayer who violates a criminal tax statute for unreported offshore income to also have willful and criminal FBAR implications as well. Here is an example of how a US Person may violate the tax evasion criminal statute in a conjunction with a willful FBAR violation.
https://www.fbarlawyersirs.com/how-ta...
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