Jack Townsend, in his Federal Tax Crimes Blog, discusses United States v. Horowitz, ___ F.3d ___, 2020 U.S. App. LEXIS 33074 (4th Cir. 2020).
OVDP has been discontinued, but a similar risk is encountered in making the decision to join the Streamlined program which requires a certification of non-willfulness with supporting narrative facts. Streamlined was designed in party to avoid having to join OVDP and opt out. But willful actors take the chance of opt out or attempting a Streamlined disclosure.
To see the full article, click: Fourth Circuit Holds Taxpayer Liable for Willful FBAR Penalty
To download the full opinion, click United States v. Horowitz, ___ F.3d ___, 2020 U.S. App. LEXIS 33074 (4th Cir. 2020)
Posted by Bella Hoang, Associate Editor, Wealth Strategies Journal
