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Analysis

'Willfulness' In Civil FBAR Cases Comes Down To The Facts

By Natalie Olivo (November 21, 2017, 6:15 PM EST) -- A judge's recent decision to let a pharmaceutical CEO escape civil penalties for failing to report his Swiss bank account doesn't necessarily signal that courts could be a reliable counterweight against the IRS' dwindling sympathy, tax specialists say, but instead highlights the fact-dependent approach for determining willful nondisclosure....

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