The U.S. Court of Appeals for the Fourth Circuit provided tax collectors with some hope last month in an unpublished July 20 opinion that reversed a Virginia district judge's decision in favor of a taxpayer. The lower court found the government failed to prove J. Bryan Williams "willfully" failed to file a foreign bank account report, or FBAR. The appeals court said his willfulness was proved by checking the "no" box for foreign bank accounts on his personal income tax return and signing it under penalty of perjury.
Offshore Tax Compliance Chair Kevin Packman said the appellate reversal in Williams was somewhat of a surprise. But he noted the case was an especially egregious set of facts where the taxpayer ignored the advice of his accountant.
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