Knowledge of FBAR Existence & Willfulness | FBAR Lawyer Beverly Hills Los Angeles California

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Hello, and welcome to Sherayzen Law Office video blog. My name is Eugene Sherayzen and I am an international tax attorney and owner of Sherayzen Law Office, Ltd.

Today, we are continuing our series of vlogs from Beverly Hills, California and today I’d like to talk to you about FBAR compliance and particular where an obligation to file an FBAR was known to the taxpayer but the taxpayer has not acted on it. Is the taxpayer’s inaction in and of itself sufficient to automatically prove early non-compliance was willful and the answer is no, automatically no. We have to look at all facts and circumstances but is this a negative fact? Absolutely. The passage of time between the time when the taxpayer learned about the existence of FBAR and when he took action is a very important consideration, not only for the reasonable cause purposes, but also for non-willfulness purposes.

If you would like to learn more about FBAR compliance, in particular the issue of willfulness vs. non-willfulness, in the context of FBAR non-compliance, call me at (952) 500-8159 or you can email me at: [email protected]

Thank you very much and until the next time.

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Knowledge of FBAR Existence & Willfulness | FBAR Lawyer Beverly Hills Los Angeles California
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Knowledge of FBAR Existence & Willfulness | FBAR Lawyer Beverly Hills Los Angeles California
Description
A failure to file FBAR while knowing about its existence is a highly important fact in the determination of what type of FBAR penalties may apply to your case. In this vlog, Mr. Sherayzen, an international tax lawyer and owner of Sherayzen Law Office, Ltd., discusses this very important issue of knowledge of FBAR existence and whether it may automatically result in willful FBAR penalties. This vlog part of a series of vlogs Mr. Sherayzen made in Beverly Hills, Los Angeles, California.
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Sherayzen Law Office, Ltd.
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