Gov't Sues To Collect Willful FBAR Penalties From Floridian

A Florida resident should have known about the requirement to report his offshore bank accounts to the Internal Revenue Service, U.S. government attorneys told a Miami federal court, contending he should hand over unpaid penalties for late filings. (U.S. v. Slochowski, case number 1:21-cv-22596, in the U.S. District Court for the Southern District of Florida).

Avishai Slochowski either knew or should have known about his obligation to file a foreign bank and financial account form, or FBAR, for Swiss and Peruvian accounts he held from 2005 through 2012, the government told the court in a complaint Wednesday. Government attorneys asked the judge to order Slochowski to pay slightly more than $888,000 in civil penalties for willfully failing to timely file FBARs, including interest and late payment penalties.

Slochowski applied in 2014 for the IRS' Offshore Voluntary Disclosure Program, designed for willful nonfilers to come forward in exchange for protection from potential criminal liability and terms for resolving civil tax and penalty obligations, according to the government. As part of the program, Slochowski filed untimely FBARs and was later removed from the OVDP due to his failure to provide truthful answers regarding his dual U.S.-Peru citizenship, among other matters, the government said.

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