A U.S. taxypayer who failed to disclose her foreign financial accounts to the IRS will not face criminal prosecution, and has avoided any FBAR penalties as well.
The taxpayer’s counsel persuaded the IRS that the taxpayer’s failure to disclose the accounts and her failure to pay taxes on the income from the accounts were non-willful, and that the case should be resolved civilly. No FBAR penalties were imposed.
The taxpayer was represented by Douglas E. Kingsbery of Tharrington Smith, L.L.P. in Raleigh, North Carolina.