Welcome to Chamberlain Hrdlicka's Tax Blog where we provide news and analysis of current legal issues facing tax practitioners.
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Over the weekend, a variety of Canadian news sources (see, e.g., the Financial Post and the Edmonton Journal) reported on anticipated guidance from the IRS, which would result in the waiver of penalties on certain U.S. citizens living in Canada for past failures to file Form TD F 90-22.1, commonly known as the "FBAR." According to the news reports, the IRS will waive failure-to-file penalties for such individuals who file delinquent tax returns and FBARS so long as the individual owes no taxes. In addition, taxpayers who were unaware of the FBAR filing requirement will be able to file ...


