Update on IRS Treatment of Civil FBAR Penalties: A Move Toward Fairness (Massachusetts Tax Alert)

Wednesday, June 3, 2015

Recently, the IRS released an internal memorandum to employees providing interim guidance on FBAR (Report of Foreign Bank and Financial Accounts) penalties. The memorandum provides guidance on the application of fairness in the IRS examiner’s determination of applicable FBAR penalties. Download our analysis of the memorandum below.