Criminal Penalties in the Internal Revenue Code and Bank Secrecy Act

Summary

This practice note discusses criminal penalties in the Internal Revenue Code and the defenses to those penalties. It also discusses the closely related penalties under the Bank Secrecy Act for failing to file Reports of Foreign Bank and Financial Accounts (FBARs). The note includes an overview of various criminal penalties including willful failures, filing false documents, tax evasion, understatements, preparer penalties, and Title 31 penalties for failing to file reports FBARs.