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News:News Commentary
Responding To The Bittner FBAR Decision - The IRS ”Resets” The Penalty Principles
August 15, 2023 - Participants include:
Virginia La Torre Jeker - @VLJeker
John Richardson - @Expatriationlaw
Out with the "mitigation provisions" and a reminder that penalties for the failure to keep records can result in a separate penalty!
On August 10, 2023 Virgina La Torre Jeker published a post about the great FBAR penalty reset - the IRS response to the Bittner decision.
It's all about the new IRS FBAR Guidance Memorandum which took effect on July 6, 2023.
You can read it here:
https://www.irs.gov/pub/foia/ig/sbse/sbse-04-0723-0034-redacted.pdf
Clearly this is NOT "good news" for taxpayers (or should it say individuals with bank and financial accounts outside the United States).
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