In a recent decision, the United States Tax Court ruled that the Internal Revenue Service (IRS) cannot assess penalties under IRC Section 6038(b) for willfully failing to report foreign income in the case of Farhy v. Commissioner. This ruling has significant implications for taxpayers who may have ...
International Tax
The case of United States v. Colliot (2018) involves Dominique G. Colliot, a U.S. taxpayer who failed to file the required FBARs for his foreign bank accounts. The Internal Revenue Service (IRS) assessed penalties against Colliot for both non-willful and willful FBAR violations. Colliot contested ...