It's been awhile since we last discussed the rights that taxpayers have to challenge the IRS through appeals.
Let's pick up the thread of our discussion of civil forfeiture from last month. In recent years, the IRS and other government agencies have often been quick to seize assets for suspected violations of the Bank Secrecy Act or other laws - even in cases where no criminal charges are ever filed. We discussed this problem in our May 8 post.
When it comes to tax noncompliance, intent can make a significant difference in terms of the penalties a taxpayer faces. When the Internal Revenue Service investigates noncompliance, there are certain things auditors will investigate to get a better handle on the intent of the taxpayer. This is where the distinction between negligence and fraud is critical.
For taxpayers without foreign bank accounts, filing season comes only once a year, in April. But if you have reporting obligations for a non-U.S. account, there is a second filing deadline that comes at the end of June. The applicable form for this second filing is now called FinCEN 114, though it is still widely known as the FBAR.
The filing deadline for foreign bank accounts that meet certain monetary thresholds is only a few weeks away. As in past years, the deadline is June 30.