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No Criminal Charges or FBAR Penalties for Failure to Disclose Foreign Accounts
A U.S. taxypayer who failed to disclose her foreign financial accounts to the IRS will not face criminal prosecution, and has avoided any FBAR penalties as well. The taxpayer’s counsel persuaded the IRS that the taxpayer’s failure to disclose the accounts and her failure to pay taxes on the income from the accounts were non-willful,
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The Tax Man Cometh: Criminal Tax Worries When the IRS Wants to Audit
You’ve known for several years that this day could come, but you’ve managed by convincing yourself that “I’m not really doing anything much different than plenty of other taxpayers,” …

