Whether a taxpayer is required to file IRS Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts, is…
TPP | Civil Penalties for Willful Violations of FBAR Requirements
Will the Fifth Circuit Clarify the IRS’s Burden of Proof?
District courts and other authorities disagree on whether the IRS must prove willfulness by a preponderance of the evidence or by clear and convincing evidence…