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Criminal Enforcement of FBAR Filing Requirements
With this year's June 30 deadline for the Foreign Bank Account Reports (FBAR) fast approaching, it's worth considering the federal government's increased attention to the FBAR rules. Though criminal and civil enforcement relating to persons failing to comply with FBAR reporting requirements has been rare, the IRS (now the agency principally responsible for FBAR compliance) appears to be gearing up to investigate and prosecute willful violators. This new emphasis, together with the IRS's ever-expanding ability to obtain once secret information from foreign jurisdictions, suggests that we will be seeing more investigations and prosecutions in this area.
FBAR Reporting Requirements
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