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4 Key Defenses In FBAR Liability

Law360, New York (August 7, 2017, 11:57 AM EDT) -- In 2007 Bradley Birkenfeld blew the whistle on UBS’s facilitation of U.S. tax evasion, and the status of offshore bank and financial accounts has not been the same since. The last decade has seen the Internal Revenue Service markedly increase its emphasis on enforcing U.S. tax law with respect to offshore bank and financial accounts owned by U.S. taxpayers.

A byproduct of the IRS’s focus on offshore accounts has been an increase in enforcement of Foreign Bank Account Report (FBAR) filing obligations, at times resulting in the imposition of huge penalties. For instance, Ty Warner, the inventor of Beanie Babies, was...

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