Willful FBAR Violations: Distinguishing Willful and Nonwillful, Relevant Factors, Mitigating Penalties
Recording of a 110-minute CPE webinar with Q&A
This webinar will examine the most recent and notable cases and guidance surrounding FBAR violations. Our astute panel will cover the factors differentiating willful and nonwillful violations, what constitutes willful blindness, enforcement measures, and steps taxpayers can take to mitigate and avoid FBAR penalties.
- FBAR: background
- Nonwillful violations
- Facts contributing to willful violations
- Facts contributing to nonwillful violations
- Relevant cases
- Mitigating penalties
- Enforcement measures
- Best practices
The panel will review these and other critical issues:
- Factors that contribute to a willful FBAR violation classification
- Strategies to avoid willful FBAR violations and penalties
- Notable cases and guidance surrounding FBAR noncompliance
- What is willful blindness and how does this affect the classification of FBAR penalties?
Ronald Kalungi, JD, LLM
Director of International Tax
Drucker & Scaccetti
Mr. Kalungi provides tax planning, tax compliance and business consulting services to a broad base of clients including... | Read More
Mr. Kalungi provides tax planning, tax compliance and business consulting services to a broad base of clients including multinational corporations, partnerships, S Corporations, and high-net-worth individuals.Close
Patrick J. McCormick, J.D., LL.M.
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting... | Read More
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting obligations. He published national articles and given numerous national and local presentations on assorted areas of tax and estate planning law, including international tax and offshore compliance issues. His latest article on PFICs is titled Tax Reporting Implications of Foreign Mutual Funds. He is licensed to practice in the States of New Jersey, Florida, and Georgia, and the Commonwealth of Pennsylvania.Close