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Video instructions and help with filling out and completing Willful vs non willful fbar

Instructions and Help about Willful vs non willful fbar

Hello Anthony hello Claudine we are here today to talk about an F Bar litigation win we like to stay on top of these because there's not a ton of Fr litigations happening that's right okay so this is Jeffrey P Pomerance he's a dual US Canadian citizen he had two overseas accounts one in Canada at CIBC in his own name Israel the other was in Switzerland under a shell companies named if he did not file F bars on either account from 2022 to 2022 so this ended up going to court yeah it did it did it did go to court so this is what happened in the case the IRS is in charge of assessing the title 31 f bar penalties even though the IRS is a twenty title 26 agency the reason being is because the title 31 F bar form it's so low value for intelligence and there's so much of it the only agency that can actually handle it isn't the agency who publishes the form that's the Financial Crimes enforcement Network is their form yet they don't want to touch it because it's a waste of their time so they all option they ship it off to the IRS to handle and the IRS has developed its own penalty procedures for assessing F bar penalties and in this case willful f bar penalties and when I read the the complaint that the Court opinion says there was two overseas accounts it looks like there's three can't quite tell not that matters much the the the result is still the same a fantastic win for mr. Pomerantz who did represent himself at awesome that's pretty awesome I pretty sure he had some help because he was trying to also move the case to the Washington DC where he had an attorney who was willing to help him so I'm wondering if that attorney helped them at all on this brief who would know maybe just some legal research he was not representing him in court of course so I mean it just went incredibly well he did lose on the motion to to change the venue where his attorney could represent him but it wasn't so important because the victory was when something like this so the IRS assess these willful penalties against them and this is oh yeah so you had yet these assets because you didn't file the f bar boom willful f bar penalties that's the standard the IRS constantly want so what you just didn't even file this therefore we should go for willful the court here we have a course a low back off to kind of need a little bit more than just not filing an F button if you are going for a non-willful penalty okay you got them you didn't file the f bar and now because you're going for the willful penalties you have the burn of proof you have to allege additional.

FAQ

What are the conditions required for non-willful FBAR violation with no penalty (FBAR warning letter, Letter 3800)?
This is what I do every day for citizens who didn’t know about their FBARs. So when I say what works, I know it does indeed work because it works for me every day.You asked what the worst is. The worst is a fine of 20% or $10,000, whichever is greater, for each year you didn’t report the existence of each foreign account times a minimum of six years. Think about the size this penalty would be more than what’s in the bank accounts now. And that, my friend, is in violation of the Eighth Amendment: cruel and unusual punishment. These amendments have lots of words and one tiny clause in this particular amendment is the bit about excessive fines being considered to be cruel. The IRS knows that they’ve been tasked with a job that, if someone they’ve caught takes it all the way up to the Supreme Court, not only will they lose but they will also have to pay back countless of fines that people paid which relied upon the same cruel fine. Thus, every single case is settled out of court. Every. Single. One. Several have made it quite far into the court process, even up to tax court, but all eventually had the guilty party cave in and pay less than the total fine in order to avoid it going to Supreme Court.Which brings us up to who to choose to represent you. You choose an attorney or accountant who is fearless because they *know* the IRS is going to cave in under pressure. As the others say, you don’t do it yourself because if you do, you’ll end up with a fine of somewhere between 5% and 27.5% on a bigger number than a creative accountant or lawyer. The good accountant or lawyer comes up with all sorts of reasons why this account shouldn’t be considered and that account is exempt. They then usually get the rate you face to be 5% or with really good ones 0% of this much smaller number.The best fines are 0% if you live outside the US at the time you file and often 0% but otherwise 5% of as small a number as they can wangle for your bank balances offshore.
How long after I fill out a non provisional patent application, will my product be safe to market?
Never, but don't be afraid.By "safe" I assume that you mean a combination of your ability to make the product free of claims of infringement, your ability to exclude other from using it and your ability to prevent others from patenting the same thing.  I also assume that you are filing in the United States.  If not, this answer may not fit.Don't worry about copyists.It is true that people are free to make copies of your product today, tomorrow and every day in the future until the patent issues.  I think a supermajority of my clients worry that as soon as their idea escapes their lips everyone will start copying it.  Yet, that virtually never happens.  Why?If you sell your product widely (assuming it's unique and people want it) then you will sell at the highest price the market is willing to pay at the quantity which corresponds to the best per unit profit.  If someone else wants to come into the market the quantity will increase and the price will fall (that is the law of demand).  The second mover will have to consider whether it is profitable to sell at this new lower price, not whether it is profitable to sell at your monopolist price.  If this new price is below its cost curve, the second mover will not enter the marketplace.  Until an economy of scale is reached, no one will want to enter the marketplace."But what about really big companies," most clients who have never worked for a big company ask, "can't they make my product for much less than me?"  Yes, but they won't.  Here, the problem isn't variable cost, but rather that new products are only viable if they are able to cover their share of the massive overhead large companies have.  If the contribution margin is less than 40% (it probably is) they will pass.  Inventors often confuse copying with independent inventorship.  The former requires a transmission of your invention to the copyist, which the copyist then copies.  This is like a copy machine.  Independent inventorship occurs when two people are trying to solve the same problem at the same time.  It is still rare that this occurs, but it does happen.  In my last thousand cases I have seen one instance of copying and maybe half a dozen cases of independent inventorship.  This is not something to worry about.You can't do anything about infringementA patent is a right to exclude, not a right to make and use your invention.  If a portion of your device is covered by another patent, you may be infringing that patent even though you have a patent on your own device.Let's say you  have a patent on a peanut butter and jelly sandwich and that you are going to a patent infringement picnic.  You see the following:A peanut butter sandwich - no jelly no infringement.A peanut butter, jelly and ice cream sandwich - you find this impressive, and you speak to the assignee to learn that it has patent on this sandwich.  Nonetheless, it still infringes because there is peanut butter, jelly and sandwich.Filing and publishing your application with thwart a subsequent or simultaneous inventorA patent requires novelty and non-obvious over that which currently exists.  Novelty means that you cannot patent something that is available to the public.  Non-obvious prevents you from patenting something that is not available to the public but the public could figure out how to make your product given what is available and the skill in your field.Publishing your application creates a searchable prior art reference for a patent examiner to easily reject a later filed application.  Of course, the sales I advised you to make above could do the same thing, but the patent examiner may not have access to those and you might have a situation where the subsequent filer gets a patent that is not enforceable.Publication carries risk as well (most notably making life easier for copyists).  To figure out the best system to handle these risks requires a much more detailed assessment of your business.  If you PM me I can try to help you.
Why don't schools teach children about taxes and bills and things that they will definitely need to know as adults to get by in life?
Departments of education and school districts always have to make decisions about what to include in their curriculum.  There are a lot of life skills that people need that aren't taught in school.  The question is should those skills be taught in schools?I teach high school, so I'll talk about that.  The typical high school curriculum is supposed to give students a broad-based education that prepares them to be citizens in a democracy and to be able to think critically.  For a democracy to work, we need educated, discerning citizens with the ability to make good decisions based on evidence and objective thought.  In theory, people who are well informed about history, culture, science, mathematics, etc., and are capable of critical, unbiased thinking, will have the tools to participate in a democracy and make good decisions for themselves and for society at large.  In addition to that, they should be learning how to be learners, how to do effective, basic research, and collaborate with other people.  If that happens, figuring out how to do procedural tasks in real life should not prmuch of a challenge.  We can't possibly teach every necessary life skill people need, but we can help students become better at knowing how to acquire the skills they need.  Should we teach them how to change a tire when they can easily consult a book or search the internet to find step by step instructions for that?  Should we teach them how to balance a check book or teach them how to think mathematically and make sense of problems so that the simple task of balancing a check book (which requires simple arithmetic and the ability to enter numbers and words in columns and rows in obvious ways) is easy for them to figure out.  If we teach them to be good at critical thinking and have some problem solving skills they will be able to apply those overarching skills to all sorts of every day tasks that shouldn't be difficult for someone with decent cognitive ability  to figure out.  It's analogous to asking why a culinary school didn't teach its students the steps and ingredients to a specific recipe.  The school taught them about more general food preparation and food science skills so that they can figure out how to make a lot of specific recipes without much trouble.  They're also able to create their own recipes.So, do we want citizens with very specific skill sets that they need to get through day to day life or do we want citizens with critical thinking, problem solving, and other overarching cognitive skills that will allow them to easily acquire ANY simple, procedural skill they may come to need at any point in their lives?
Do I need to file an FBAR if I moved out of the USA but still liable for tax as a US non-resident?
A U.S. person must file an FBAR (Foreign Bank and Financial Accounts) if that person has a financial interest in or signature authority over any financial accounts outside of the U.S. and the aggregate maximum value of the account(s) exceeds $10,000 at any time during the calendar year.A person is considered to be a U.S. person if the person is:A citizen of the U.S., orA lawful permanent resident of the U.S., U.S. territories, U.S. possessions, or federally recognized tribal land any time during such calendar year, orA U.S. alien who meets the substantial presence test, orA U.S. alien who has made a first-year election to be treated as a resident for tax purposes, orA corporation, partnership, limited liability company, trust, estate, or other entity created or organized in the U.S. or under the laws of the United States.The substantial presence test is a bit lengthy to explain. See the IRS web site for more information. Substantial Presence TestSee the FBAR reference guide for further information and details. https://www.irs.gov/pub/irs-utl/...See 26 U.S. Code Section 7701(b) for more information. 26 U.S. Code § 7701 - Definitions
How much will be the fee to fill out the XAT form?
The XAT Registration fee is Rs. 1700(late fee Rs. 2000). This is had increased from last year.If you want to apply for XLRI programmes then pay additional Rs.300 (late fee Rs. 500)The last date for registration is 30th Nov 2022. The exam is on 6th Jan 2019.All the best
Would Russia and China have a chance at winning a non-nuclear war against the US?
It would depend on the nature of the war and where it takes place.No one could invade the U.S There is one crucial data point that will determine the outcome of an attempt to invade the U.S. The US has 6 or 8 carrier fleets. No one has even one carrier group that would match even one US carrier fleetSo the US could use air power to demolish the invading force.But what if the battle was less than a war? Or what if there were a series of battles in Asia or Europe? Then look at Vietnam. The US was clearly stronger as a military power. Yet after over 10 years the U.S. left.
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