U.S. citizens and residents with financial interests in foreign accounts that exceed $10,000 at any time in a year must file an FBAR. The failure to file an FBAR can be costly. If the government shows ...
In recent years, the government has made concerted efforts to win willful FBAR penalty cases through summary judgment motions. This is not surprising. Thus far, it has convinced courts that ...
The issue of willfulness is very important in FLSA cases because such a finding extends the statute of limitations from two years to three. The standards utilized in making these decisions have been ...
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