# IRS pursues Canadian resident for wilful FBAR penalties



## iota2014 (Jul 30, 2015)

This was reported on a Canadian tax firm's blog (US Government sues Canadian resident US citizen for 860K in penalties | SKL) and some mainstream Canadian media (U.S. sues Vancouver dual citizen for over $1M for not reporting accounts - National | Globalnews.ca, U.S. government suing Canadian resident for $1.1M over bank form - Politics - CBC News).

The taxpayer's circumstances are far from clear; however, it seems the FBAR penalties are not the main issue, but arose as a consequence of ongoing investigations into (as alleged by the IRS) several accounts in Switzerland, a ****tive shell company registered in Turks&Caicos, and under-reporting of income/assets while resident in the US.

Whatever the rights and wrongs, this is clearly *not* a case of the IRS trying to inflict wilful FBAR penalties for no other reason than failure to report a local account. 

Interesting, though, because the court transcripts (https://www.documentcloud.org/documents/3518799-Pomerantz.html, https://www.documentcloud.org/documents/3518808-Pomerantz2.html, links posted on IBS) show just how tricky it is for the IRS to collar a non-US-resident USC who doesn't want to be collared. 

It does seem likely that innocent didn't-know CBT victims can sleep the sleep of the just provided they're not too rich and not-knowing is their only crime.


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## andie17 (Feb 21, 2017)

LOL what a difference between the Global News article and the Court Transcripts.

I read the news article first and it appeared Pomerantz was some poor smuck, scraping by on his government pension, that just made a mistake filing his own taxes, and this brought up my concerns that at some point I may make a mistake and forget something.

The Court documents portray quite the different scenario.


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## andie17 (Feb 21, 2017)

It also occurs to me that Canada Revenue Agency might be interested in his offshore companies.


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