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 2023 to 2023 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...
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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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