A recent US District Court case was decided in favor of
the IRS and imposed foreign account reporting obligations
on a taxpayer that opened an account with an online
poker company. The online account was a foreign account
because the online poker company was a foreign company,
and the account’s location was determined by the location
of the institution.
The ruling illustrates the expansive view the government
takes in relation to a taxpayer’s obligation to disclose the
existence of a foreign account under the Foreign Bank
and Financial Accounts Report (FBAR) rules. If you have
questions about your FBAR obligations, please contact
David Guarino or Cory Bilodeau, the Co-Chairs of the
Tax Practice at Fletcher Tilton.