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Jacqueline Titus

Jacque Titus is an associate in the North America Tax Practice Group and resides in the Firm's Dallas Office. She advises US and multinational companies on domestic and international tax planning and transactions.

The Northern District of California recently determined that a taxpayer’s failure to timely file Reports of Foreign Bank and Financial Accounts (FBARs) was willful for two of four years at issue because the taxpayer affirmatively acknowledged the foreign accounts on the Schedules B for those years. The court found that the taxpayer’s failure to include Schedules B with the previous two years’ returns was not a willful violation, however.

Read publication We are pleased to enclose the March issue of Tax News and Developments, a publication of Baker McKenzie’s North America Tax Practice Group. This month’s edition features an update on the tax payment deadline, state and local tax effects of COVID-19, a discussion on the FDII regime, the…