Court Rejects Challenge to IRS Foreign Account Streamlining (1)

A federal court rejected a challenge to the application of an IRS program for promoting voluntary disclosure of foreign accounts and resolving penalties, ruling the challengers didn’t show the IRS entered into and breached a contract.

The challenge was brought by executors of the estate of Margaret J. Jones, who entered the IRS’s Streamlined Procedures program and in 2015 paid a miscellaneous offshore penalty of about $157,000—5% of the highest balance of the foreign accounts she held and didn’t report from 2008-2013. Under the Bank Secrecy Act, people must report their foreign bank and financial accounts if the total ...