The Seventh Circuit upheld a court conviction of an accountant and entrepreneur who failed to file reports of foreign bank accounts and committed mail and financial aid fraud. In United States v. SimonLink, James Simon could not provide a legitimate reason for his failure to file Form TDF90-22.1, Report of Foreign Bank and Financial Accounts (FBAR).
Offshore Tax Compliance Partner Kevin Packman said that FBAR notices are "relatively specific—a taxpayer only qualifies for the voluntary disclosure program if the taxpayer's failure to file was not willingful and the taxpayer is not under investigation."
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