Specifically, the indictment alleges that Booker’s actions were willful and he therefore should not have applied for the program. Interestingly, Booker is also charged with filing a false submission to the IRS Streamlined Procedures amnesty program. The indictment alleges that Booker failed to disclose a number of accounts located in Switzerland, Singapore, and Panama on FBARs, and that he filed false tax returns that failed to report the accounts. Brian Booker, a former CPA, with failing to meet the FBAR reporting requirements and filing false documents with the IRS.īooker, a former resident of Florida, owned and operated a cocoa trading company from Venezuela, Panama, and Florida. Several weeks ago, a federal grand jury returned an indictment charging Mr.
The FBAR reporting requirements apply if the individual holds the foreign account directly (or indirectly through certain entities) or has signature authority over the account. account with a mutual fund or similar pooled fund.account with a person that acts as a broker or dealer for futures or options transactions in any commodity on or subject to the rules of a commodity exchange or association.account that is an insurance or annuity policy with a cash value.account with a person that is in the business of accepting deposits as a financial agency.The IRS defines FBAR reportable accounts to include a foreign: The FBAR due date is April 15th, currently with an automatic extension of 6 months. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”). The FBAR form (officially known as “FinCEN Form 114”) must be filed electronically using the BSA E-Filing System maintained by the U.S. person file a Report of Foreign Bank and Financial Accounts (FBAR) if the maximum values of the foreign financial accounts of such person exceed $10,000 in the aggregate at any time during the calendar year. The Bank Secrecy Act (BSA) requires that a U.S. Before we get to the case, let’s quickly review the FBAR reporting requirements. In a recent federal indictment of a former CPA, the egregiousness of the taxpayer’s actions again raised the issue of the extent to which a taxpayer’s actions should be classified by the IRS as willful in nature. This key distinction significantly affects the extent to which the IRS will penalize the taxpayer. The more recent cases have given particular attention to the issue of whether the taxpayer’s failure to meet the FBAR reporting requirements was willful or non-willful. Given the renewed focus of the IRS on international tax compliance issues, it should come as no surprise that FBAR indictments and court cases are becoming increasingly prevalent. FAILING TO MEET FBAR REPORTING REQUIREMENTS SPELLS SERIOUS TROUBLE FOR FORMER CPA
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