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Whistleblowers and FBAR Penalties


The IRS has determined that the whistleblower award provided in 7623, here, does not allow awards for information leading to FBAR penalties.  Practitioners have questioned the propriety and the wisdom of  that interpretation.
The issue seems to turn upon whether the scope of Section 7623 covers collections related to non-tax matters administered by the IRS.
This possibility should give at least the bigger players in the offshore evasion game some concern.  Even if Section 7623 were not to cover FBAR penalties, it would cover any of the related penalties (such as the 5471 penalty and the 3520 penalties).

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