This Daily Tax Tip Spotify Podcast and/or WordPress Blog Post discusses when an Estate Owes $6.4 Million for Decedent’s Failure to File FBARs.
In U.S. v. Est. of Danielson 2020 PTC 352 M.D. Fla 2020, a district court granted the government’s request for a default judgment against a decedent’s estate for civil penalties and fees of more than $6.4 million as a result of the decedent’s failure to file foreign bank account reports (FBARs).
The court noted that the decedent had filed FBARs in 1994 and 1995 thus proving that he knew of his obligation to file an FBAR in subsequent years, but yet had, under penalty of perjury and with knowledge of his bank accounts in Lichtenstein and Canadian, checked “no” on his tax returns when asked if he had a foreign bank account which, the court said, proved that he acted willfully in failing to report his ownership and interests in his foreign bank accounts.
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