Mitigating the Risk of Large FBAR and International Tax Claims

August 8, 2023

Mitigating the Risk of Large FBAR and International Tax Claims

August 8, 2023

Stay informed and vigilant: Rising severity of international tax filing claims poses new challenges for CPA firms.

The frequency and severity of malpractice claims related to tax services provided by CPA firms may be changing. Errors and omissions in international tax filings, specifically related to U.S. filing obligations for foreign activity, are leading to more severe claims. The penalties for non-compliance with international tax filing requirements can range from $10,000 to over $1,000,000. The severity of these claims is increasing because the IRS is assessing penalties more frequently and abating them less often. Common reasons for claims related to international tax filings include not identifying filing requirements, not asking enough questions to identify filing obligations, and forgetting to file or extend forms on time. Risk management recommendations include training to understand international filing requirements, using well-written engagement letters to define the scope of services, using organizers and checklists with comprehensive questions, and documenting discussions with clients. Recent court decisions may provide some penalty relief, but the IRS's response and the persistence of large penalties related to noncompliance are still a concern. For more information click the link!

https://www.journalofaccountancy.com/issues/2023/jul/mitigating-risk-of-large-fbar-and-international-tax-claims.html

Kwong v United States
May 29, 2026
Learn how the Kwong v. United States decision may create IRS penalty refund opportunities for businesses that paid penalties during the COVID disaster period.
May 26, 2026
Section 179 vs Bonus Depreciation: Which Strategy Is Right for Mid-Market Companies?
Nexus tax exposure map showing multi-state risk for growing businesses
May 19, 2026
Nexus tax exposure can be triggered by revenue alone. Learn how multi-state businesses can identify risk, avoid penalties, and strategically manage tax obligations.
Bonus Depreciation 2025 Strategy Guide
May 11, 2026
Bonus depreciation in 2025 requires strategic timing. Learn when to accelerate deductions and when deferring can create greater long-term value for growth companies.
IRS tax debt tool for businesses
April 29, 2026
The IRS’s new tax debt tool signals a shift toward earlier visibility and accountability. Learn what this means for established, multi-entity businesses.
ASC 740 errors don’t just create restatement risk.
By Tim Freese April 7, 2026
Learn how ASC 740 tax provision errors affect financial statements, earnings quality, valuation allowances, and lender confidence.
Engineering Solutions? You May Be Generating Tax Credits.
By Tim Freese March 31, 2026
Learn how manufacturers and SaaS companies can systematically capture R&D tax credits under IRC Section 41 and maximize federal tax savings.
I
By Tim Freese March 24, 2026
Own commercial property? Learn how cost segregation accelerates depreciation, unlocks bonus deductions, and improves cash flow strategy.
By Tim Freese March 17, 2026
Learn how CFOs can strategically manage multi-state tax exposure, economic nexus, apportionment, and payroll risk across jurisdictions.
Exit planning is not triggered by a buyer.
By Tim Freese March 10, 2026
Planning a business exit? Learn how entity structure, QSBS, and deal modeling can determine millions in after-tax proceeds.