Government Seeks Judgment for FBAR – What Does it Mean?

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Government Seeks Judgment for FBAR - What Does it Mean? (Golding & Golding, Board-Certified Tax Specialist)

Government Seeks Judgment for FBAR – What Does it Mean? (Golding & Golding, Board-Certified Tax Specialist)

Government Seeks Judgment for FBAR – What Does it Mean?

Generally, when the government seeks judgment for FBAR, it is after the IRS has assessed FBAR penalties, and the defendant has not paid the government for the penalties tht were assessed.

Government Seeks Judgment for FBAR

When the government seeks judgment involving FBAR, it usually includes two main issues:

  • Motion for Summary Judgment; or
  • Motion for Default Judgment

Motion for Summary Judgment (FBAR)

In a motion for summary judgment on FBAR issues, either party is seeking to avoid a long, drawn-out trial on a particular issue (or issues).

For example, a Taxpayer may want to seek summary judgment (or at least “partial summary judgment”) against the IRS.

One recent example was in the case of Horowitz, when the spouse of the main defendant (her husband) was able to secure a “partial” summary judgment on certain issues involving her requirements to file an FBAR.

Motion for Default Judgment (FBAR)

With a default Judgment, the U.S. seeks a judgment against defendant, when defendant fails to participate in the litigation. One example is that the lawsuit is filed and the complaint is served — but the Defendant does not file an answer.

We Specialize in FBAR & FATCA (Board-Certified Tax Specialist)

We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants and Financial Professionals worldwide.

Less than 1% of Tax Attorneys Nationwide Are Certified Specialists

Sean M. Golding is one of less than 350 Attorneys (out of more than 200,000 practicing California Attorneys) to earn the Certified Tax Law Specialist credential. The credential is awarded to less than 1% of Attorneys.

Recent Golding & Golding Case Highlights

  • We represented a client in an 8-figure disclosure that spanned 7 countries.
  • We represented a high-net-worth client to facilitate a complex expatriation with offshore disclosure.
  • We represented an overseas family with bringing multiple businesses & personal investments into U.S. tax and offshore compliance.
  • We took over a case from a small firm that unsuccessfully submitted multiple clients to IRS Offshore Disclosure.
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How to Hire Experienced Streamlined Counsel?

How to Hire Experienced Streamlined Counsel?

How to Hire Experienced Streamlined Counsel?

Generally, experienced attorneys in this field will have the following credentials/experience:

  • Board Certified Tax Law Specialist credential
  • Master’s of Tax Law (LL.M.)
  • Dually Licensed as an EA (Enrolled Agent) or CPA
  • 20-years experience as a practicing attorney
  • Extensive litigation, high-stakes audit and trial experience

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