Federal Tax Crimes: Fourth Circuit Holds Taxpayer Liable for Willful FBAR Penalty (10/21/20)

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

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