Certain taxpayers who are citizens of foreign countries also have green cards granting them resident status in the United States. Some argue the laws regarding their obligation to file FBARs are unconstitutionally vague.
Archives June 10, 2017
Court Finds That the Criminal Offense for a U.S. Resident’s Willful Failure to File an FBAR was Not Unconstitutionally Vague
The Applicable Federal Sentencing Guideline for a Violation of Internal Revenue Code Section 7212.
Written by on in Tax Audits, Appeals & Litigation.
Section 7212 of the Internal Revenue Code punishes intentional attempts to interfere with the IRS’s administration of the Internal Revenue laws.