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Important Supreme Court Decision will Decide how Non-Willful FBAR Penalties are Calculated

This fall, the Supreme Court is set to hear an important case regarding the interpretation of the law that provides for penalties for failing to file an FBAR. The case will impact many taxpayers who have already been...more

Significant Revisions to the IRS Offshore Voluntary Disclosure Program

The existing OVDP has been in place since March 2009. The program allows a taxpayer to voluntarily come into compliance with US tax reporting obligations and pay a reduced civil penalty rather than facing either greater...more

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