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Tag Archives: WILLIAMS CASE
WILL-O -THE WISP NON-WILLFULNESS IN THE STREAMLINED FILING COMPLIANCE PROCEDURE
“A will-o’-the-wisp is an atmospheric ghost-light seen… at night, especially over bogs, swamps or marshes. It resembles a flickering lamp and is said to recede if approached, drawing (sojourners) from the safe paths.”(Wilkipedia). Most clients with unreported offshore accounts who … Continue reading →
Posted in TAX
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Tagged BANK SECRECY ACT, CERTIFICATION OF NON-WILLFULNESS, FBAR PENALTIES, FBAR QUESTION ON SCHEDULE B, FBARS, FOREIGN BANK ACCOUNTS, IRS STREAMLINED FILING COMPLIANCE PROCEDURES, MCBRIDE CASE, NONWILLFULNESS, OFFSHORE ACCOUNTS, OFFSHORE BANK ACCOUNTS, OFFSHORE TAX FRAUD, ROBERT S STIENBERG, VOLUNTARY DISCLOSURE, WILLFULNESS, WILLIAMS CASE
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