Each year, the Internal Revenue Service’s Criminal Investigation Division (IRS CI) releases a report highlighting its achievements over the past 12 months. IRS CI recently released its FY 2021 Annual Report; and, as usual, the report spotlights many of the division’s top enforcement priorities. As these priorities typically carry over into the following year, understanding where IRS CI focused its enforcement efforts in 2021 will be instructive for U.S. taxpayers seeking to avoid unwanted scrutiny in 2022. Washington D.C. tax attorney Kevin E. Thorn, Managing Partner of Thorn Law Group, explains.

Under the federal Bank Secrecy Act (BSA), U.S. taxpayers who own qualifying offshore accounts and other foreign financial assets are required to file a Report of Foreign Bank and Financial Accounts (FBAR) on an annual basis. Failure to comply with the BSA can lead to steep penalties—even if the failure is inadvertent. With this in mind, U.S. taxpayers who discover that they are behind on their FBAR filings must take proactive steps to come into compliance. As Washington D.C. international tax attorney Kevin E. Thorn, Managing Partner of Thorn Law Group, explains, this may mean submitting a statement of “reasonable cause.”

The automatic extension for filing an FBAR expired on October 15, 2021. If you haven’t yet filed an FBAR for the 2020 tax year, your FBAR is now late. As the IRS noted in a recent reminder, “[t]hose who don't file an FBAR when required may be subject to significant civil and criminal penalties.” Here, Washington D.C. international tax attorney Kevin E. Thorn, Managing Partner of Thorn Law Group, explains what you should do if you need to file a late FBAR.