FBAR 2019 Update: FinCen Form 114, Deadlines, Extension, Penalty Resolution and Waiver Provisions

Who Must File, What Must Be Reported, Willful vs. Non-Willful Failures

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A


Conducted on Tuesday, August 6, 2019

Recorded event now available

or call 1-800-926-7926
Program Materials

This webinar will provide tax advisers with a practical guide to completing required FBAR filing requirements. The panel will offer detailed instruction on completing and filing an FBAR (FinCen Form 114), discuss recent IRS penalty enforcement actions for non-filing of foreign bank accounts, and describe extension provisions for the 2019 filing year.

Description

The recent court of claims' holding that imposed an $800,000 penalty on a schoolteacher for willful failure to complete the FinCen Form 114 (FBAR) reinforces the IRS' intent to focus on foreign information reporting noncompliance as a high enforcement priority. While the form and filing requirements remain in place, FinCen and the IRS have extended some filing deadline protections to benefit taxpayers required to disclose foreign-based financial account balances.

FBAR remains a complex reporting obligation, and the IRS will cross-reference FBAR information with other tax filings, as well as information disclosures from other sources such as foreign financial institutions. This makes failure to accurately report assets on the FBAR potentially very costly for U.S. taxpayers, even with the extension provisions of the new regulations.

Listen as our experienced panel provides a comprehensive guide to completing the FBAR forms.

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Outline

  1. What triggers FBAR filing requirements
    1. Entity ownership
    2. $10,000 threshold
    3. When are a company's officers personally responsible?
  2. Information to report on the FBAR vs. Form 8938
    1. Ownership accounts, accounts with signature authority, combined report accounts
    2. Form 8938 and associated IRS forms for foreign ownership/transactions
  3. Update on enforcement and new developments
    1. FBAR and Form 8938 penalties
    2. Willfulness standard and the non-willful certification
    3. Avenues and procedures
    4. Audits and examination
    5. Civil vs. criminal sanctions

Benefits

The panel will review these and other key issues:

  • When can corporate officers' stake in foreign accounts trigger reporting responsibilities?
  • What is the latest in the IRS and FinCen enforcement activity?
  • What are the options for companies required to file an FBAR and have not?
  • How do Form 8938 filing requirements intersect with FBAR?

Faculty

Brager, Dennis N.
Dennis N. Brager, Esq.

Certified Tax Specialist
Brager Tax Law Group

Mr. Brager is a nationally known tax litigation attorney, representing clients in criminal and civil tax litigation and...  |  Read More

Drabkin, Igor
Igor S. Drabkin

Principal
Holtz Slavett & Drabkin

Mr. Drabkin represents tax clients in disputes with the IRS and state revenue authorities, both administratively...  |  Read More

Obeid, Fran
Fran Obeid

Principal
MFO LAW

Ms. Obeid is the founder of MFO LAW, P.C. She represents individual and corporate clients in civil and criminal matters...  |  Read More

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