Wednesday, March 21, 2018

FBAR Civil Penalty Items (3/21/18)

Items of interest to FBAR fans:
  • First, FinCEN has updated the inflation adjustment for the FBAR civil penalties stated in $ amounts.   See Inflation Adjustment of Civil Monetary Penalties (Final Rule Adopted 3/18/18),  revising Table 1 of § 1010.821—Penalty Adjustment and Table, here):  Those adjustments are 

Penalty
Statute
Amount as Inflation Adjusted
Nonwillful Penalty Maximum (§ 5321(a)(5)(B)(i))
$10,000
$12,921
Willful Penalty Minimum (§ 5321(a)(5)(C)(i)(1)
$100,000
$129,210

  • The National Taxpayer Advocate posted the following article on her blog:  Analysis of Tax Settlement Programs as Amnesties - When Should the Government Offer Them and How Should They Be Structured? (Part 1 of 3) (NTA Blog 3/14/18), here.  This first installment addresses the general effect of tax and tax-related amnesties.  The blog indicates: "Next week we will apply what we’ve learned about amnesties to the IRS’s OVDP.."

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