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  • Holly Roundtree CPA

2019 – 09/04

Taxpayers with certain foreign financial accounts must report them on their returns. They may also need to file a Report of Foreign Bank and Financial Accounts (FBAR) or face penalties. One taxpayer didn’t file FBARs for his Swiss accounts, prior to 2011. In 2011, he signed an agreement with the IRS to voluntarily disclose the accounts and extend the tax return review period. Later he claimed the agreement was invalid and opted out. When the IRS assessed penalties on his 2006-2009 returns, he said the assessments were made after the limitation period expired. The IRS pointed to his signed consent, and a U.S. District Court agreed that his argument was meritless. (Schwarzbaum, DC FL, 8/23/19)

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