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PREP Podcaster - ”Success Favours The PREPared Mind”

Responding To The Bittner FBAR Decision - The IRS ”Resets” The Penalty Principles

Broadcast on:
15 Aug 2023

August 15, 2023 - Participants include:

 

Virginia La Torre Jeker - @VLJeker

John Richardson - @Expatriationlaw

 

Out with the "mitigation provisions" and a reminder that penalties for the failure to keep records can result in a separate penalty!

On August 10, 2023 Virgina La Torre Jeker published a post about the great FBAR penalty reset - the IRS response to the Bittner decision.

It's all about the new IRS FBAR Guidance Memorandum which took effect on July 6, 2023.

You can read it here:

https://www.irs.gov/pub/foia/ig/sbse/sbse-04-0723-0034-redacted.pdf

Clearly this is NOT "good news" for taxpayers (or should it say individuals with bank and financial accounts outside the United States).