Hello Anthony and hello Claudine. We are here today to talk about an F Bar litigation win. We like to stay on top of these because there aren't many 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, and the other was in Switzerland under a shell company's name. He did not file F Bars on either account from 2007 to 2009. So this ended up going to court. Yeah, 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 title 26 agency. The reason being is because the title 31 F Bar form is 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, it's 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. When I read the complaint that the court opinion says there were two overseas accounts, it looks like there are three, can't quite tell, not that it matters much, the result is still the same, a fantastic win for Mr. Pomerantz who did represent himself, which is pretty awesome. I'm pretty sure he had some help because he was trying to also move the case to Washington DC where he had an attorney who was willing to...
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Willful vs non willful fbar Form: What You Should Know
The tax laws do not require the IRS to offer a penalty to violators, but instead impose a fine. The IRS sets the administrative penalty, so the 10,000 maximum will be applied in the event of a violation.3 What Happens after Filing a Willful and Non-Willful SAR? Once a Taxpayer Is Found Guilty, it is a felony charge to withhold, pay, or receive the taxpayer's amount due, whether voluntary or involuntary. This misdemeanor criminal offense could result in up to 2½ years in prison and a fine of 250,000.4 What Happens if the Amount Is Received? If you're an SAR contributor, and you're caught, there is no reason to worry. Just as the IRS is not obligated to accept a fraudulent return or return forgery, you're not liable for any penalties if you're wrongfully held back. The same goes if you are found to willfully file a non-return, which doesn't have to be a crime either under the tax laws.
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