The Resource Constructive knowledge and FBAR penalties : does merely filing a form 1040 suffice to establish "willfulness"?

Constructive knowledge and FBAR penalties : does merely filing a form 1040 suffice to establish "willfulness"?

Label
Constructive knowledge and FBAR penalties : does merely filing a form 1040 suffice to establish "willfulness"?
Title
Constructive knowledge and FBAR penalties : does merely filing a form 1040 suffice to establish "willfulness"?
Creator
Subject
Language
eng
Summary
In fighting the battle against offshore tax avoidance, the U.S. government has raised some creative arguments to establish that a taxpayer "willfully" failed to disclose foreign accounts by filing FinCEN Forms 114 (FBARs). These include the concept of "constructive knowledge". The article provides information on laws concerning penalties related to Reports of Foreign Bank and Financial Accounts (FBAR) and examines the major cases that have analyzed the "constructive knowledge" position and what they mean to taxpayers
Citation source
In: International tax journal. - Riverwoods. - Vol. 45 (2019), no. 1 (January-February) ; p. 31-40
http://library.link/vocab/creatorName
Sheppard, H.E
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • FBAR
  • penalties
  • disclosure
  • bank secrecy
  • case law
Label
Constructive knowledge and FBAR penalties : does merely filing a form 1040 suffice to establish "willfulness"?
Instantiates
Publication
Label
Constructive knowledge and FBAR penalties : does merely filing a form 1040 suffice to establish "willfulness"?
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
Processing Feedback ...