Is Mental Incapacity a Defense to Tax Penalties and FBAR Penalties?
By Sanford Millar of MillarLaw A Professional Corporation On Monday, June 27, 2016
The Tax Crimes Handbook of the Office of Chief Counsel, Criminal Tax Division of the Internal Revenue Service defines “Willfulness ” as follows: “[a] Willfulness is defined as the “voluntary, intentional violation of a known legal duty.” Cheek v. United States, 498 U.S. 192, 200-01 (1991); United States v. Pomponio, 429 U.S. 10, 12 (1976); … Continue reading Is Mental Incapacity a Defense to Tax Penalties and FBAR Penalties?
Foreign Bank Account Reports Due June 30
By Sanford Millar of MillarLaw A Professional Corporation On Sunday, May 22, 2016
U.S. Taxpayers who directly or indirectly controlled foreign financial accounts in 2015 are reminded that the deadline to file a Report of Foreign Financial Account (FBAR) FinCEN Form 114 is June 30. Taxpayers with unfiled FBARs for prior years should be aware of that the information exchange agreements under the Foreign Account Tax Compliance Act … Continue reading Foreign Bank Account Reports Due June 30