One thing people tend to forget when it comes to the FBAR (Foreign Bank account reporting):
FBARs must be filed for deceased individuals. Whoever is responsible for administrating the estate should make sure to take care of this, otherwise a large part of their inheritance could be at risk.
The IRS can go after the estate for payment or penalties.
A recent district court case against the estate of a deceased taxpayer has ruled in favor of the IRS granting over $6 million in penalties against the estate for failure to report foreign bank accounts, reinforcing the fact that death does not absolve a taxpayer from his or her FBAR reporting requirements.
See U.S. v. Estate of Danielsen, 126 AFTR 2d 2020-6366
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