The FBAR (FinCEN Form 114) goes to the Treasury Department and reports foreign financial accounts once they top $10,000 in total. Form 8938 is a FATCA form filed with your income tax return, it reports a broader set of foreign assets, and its thresholds are higher and depend on where you live and how you file.

If you cross both thresholds, you report the same accounts twice, on two forms, to two different parts of the government. This article explains the differences and who files what. To review your situation with counsel, call (415) 968-1780.

FBAR vs. Form 8938 at a glance

The two filings overlap but are not the same. Here is how they compare:

What each form actually reports

The FBAR is focused: it reports foreign financial accounts, meaning bank accounts, brokerage and securities accounts, foreign mutual funds, and certain foreign pension or cash-value insurance accounts held at an institution outside the United States. We cover the account rules in detail in FBAR filing requirements.

Form 8938 reaches wider. It reports “specified foreign financial assets,” which include the same foreign accounts plus other assets that are not held in an account at all: foreign stock or securities you hold directly, an interest in a foreign entity, and foreign financial instruments or contracts with a non-U.S. counterparty.

A useful rule of thumb is that a directly held foreign investment, such as shares in a foreign company held outside a brokerage account, can be reportable on Form 8938 even though it never appears on an FBAR. Neither form, it is worth noting, reports directly held foreign real estate or personal physical assets, though real estate held through a foreign entity can bring the entity interest into Form 8938.

The Form 8938 thresholds are higher and depend on where you live

Unlike the flat $10,000 FBAR threshold, Form 8938 thresholds vary by filing status and residence. For taxpayers living in the United States, the filing requirement generally starts when specified foreign assets exceed $50,000 on the last day of the year or $75,000 at any point for a single filer, with the figures roughly doubling for married taxpayers filing jointly.

For taxpayers living abroad, the thresholds are much higher, generally starting around $200,000 at year-end or $300,000 at any time for a single filer, and again roughly double for joint filers. Because the numbers are adjusted and applied to specific facts, confirm the current thresholds for your filing status before relying on them.

Why many people file both

The reason both forms so often apply is that their coverage overlaps in the middle. A taxpayer with, say, $120,000 spread across two foreign bank accounts and a foreign brokerage account is over the $10,000 FBAR threshold and over the domestic Form 8938 threshold at the same time, so the same accounts get reported on both forms.

Filing one does not satisfy the other, and there is no credit for having filed the other form. When in doubt, the conservative and common approach is to review both tests separately.

What about cryptocurrency?

Crypto adds a wrinkle to both forms. For the FBAR, an account holding only virtual currency is not currently reportable, though most exchange accounts also hold cash-like assets that make the whole account reportable, and the rules are changing. Form 8938 treatment of directly held crypto is likewise unsettled. We work through both in Crypto FBAR: Reporting Cryptocurrency on Foreign Exchanges.

The penalties for getting it wrong

Both forms carry serious penalties, which is why the conservative approach usually wins. FBAR penalties reach roughly $16,500 per report for non-willful violations and far more when a violation is willful, a subject we cover in FBAR Penalties: Willful vs. Non-Willful and How to Reduce Them.

Form 8938 carries a $10,000 failure-to-file penalty that can climb to $50,000 for continued failure after IRS notice, along with a 40% accuracy-related penalty on any understatement tied to an unreported asset, and a failure to file Form 8938 can keep the statute of limitations open on your whole return. The figures adjust over time, so confirm current amounts.

What to do if you missed one or both

Missing these filings is common and fixable, but the right correction depends on whether the failure was non-willful or willful. Non-willful taxpayers may be able to use the Streamlined Filing Compliance Procedures or the Delinquent FBAR Procedures, while cases involving possible willfulness point toward the formal IRS Voluntary Disclosure Practice.

Do not quietly back-file without advice. The disclosure path is a decision to make with an attorney, under privilege, before you file anything. For the full picture, see our offshore and international tax attorney page.

How Kugelman Law helps

We advise U.S. taxpayers on foreign-account and foreign-asset reporting and represent them when a filing is missed or a penalty is assessed, from sorting out which forms apply to correcting past years and defending penalties.

Our results reflect what disciplined advocacy achieves in high-stakes tax disputes. In one federal matter, two IRS Notices of Deficiency proposing more than $557,000 across six years were settled in U.S. Tax Court down to roughly $38,000, and with avoided interest and California exposure the client effectively saved over $1.2 million. Results depend on specific facts. Past results do not guarantee future outcomes.

Talk to an attorney about your foreign-reporting obligations

If you are not sure whether you owe an FBAR, a Form 8938, or both, get a privileged assessment before you file. Schedule a paid, privileged consultation with Kugelman Law by calling (415) 968-1780 or visiting our contact page.

Frequently asked questions

Do I have to file both the FBAR and Form 8938?

Often, yes. They are separate filings with different thresholds, and many taxpayers exceed both. If your foreign accounts top $10,000 at any point in the year, you file an FBAR, and if your specified foreign assets also exceed the Form 8938 threshold for your filing status, you file that form too. One filing does not satisfy the other.

What is the difference between the FBAR and Form 8938?

The FBAR (FinCEN Form 114) is filed with the Treasury and reports foreign financial accounts once they exceed $10,000 combined. Form 8938 is a FATCA form filed with your tax return, reports a broader set of specified foreign financial assets, and has higher thresholds that vary by filing status and whether you live in the U.S. or abroad.

What are the Form 8938 filing thresholds?

For taxpayers living in the U.S., the requirement generally starts above $50,000 in specified foreign assets at year-end or $75,000 at any time for a single filer, roughly doubling for joint filers. For taxpayers living abroad, the thresholds are much higher, generally starting around $200,000 at year-end or $300,000 at any time for a single filer. Confirm the current figures for your filing status.

Does Form 8938 report assets the FBAR doesn’t?

Yes. Form 8938 covers specified foreign financial assets beyond accounts, such as directly held foreign stock or securities and interests in foreign entities, which can be reportable on Form 8938 even when they never appear on an FBAR. Neither form reports directly held foreign real estate.

What happens if I file one but not the other?

You can still face a penalty for the form you missed. The filings are independent, so satisfying the FBAR does not excuse a missing Form 8938 or vice versa. If you have missed either, the correction path depends on whether the failure was non-willful or willful, and should be chosen with an attorney.

About the author

Alex Kugelman is the founder and managing attorney of Kugelman Law, with nearly two decades of federal tax controversy experience including U.S. Tax Court and U.S. District Court litigation. He is admitted in California and before the U.S. Supreme Court, the U.S. Tax Court, and the U.S. District Court for the Northern and Eastern Districts of California, and served as San Francisco Chair of the Federal Bar Association Tax Division in 2018. He is nationally recognized for cryptocurrency tax and has been quoted in the Financial Times and the New York Post on California tax enforcement. For matters that reach into IRS offshore examinations, his colleague Otto Bosch, a former IRS Revenue Agent from the Large Business & International division, leads the firm’s federal audit-defense work.

This article is attorney advertising and general information, not legal advice, and it describes rules and thresholds that can change. Foreign-reporting obligations are fact-specific. Contacting Kugelman Law does not create an attorney-client relationship.

The FBAR is FinCEN Form 114, and it is filed electronically, separately from your tax return. What trips people up is not the threshold but the definitions, because “U.S. person,” “foreign financial account,” and “signature authority” all reach further than most people expect.

This article explains who must file and what counts. To review your accounts with counsel, call (415) 968-1780.

What is the FBAR?

The FBAR, short for the Report of Foreign Bank and Financial Accounts, is an annual report of your foreign financial accounts filed on FinCEN Form 114 through the Treasury Department’s BSA E-Filing System. It is not part of your Form 1040, and filing your tax return does not satisfy it.

The obligation comes from the Bank Secrecy Act, not the Internal Revenue Code, which is one reason it is so easy to miss and why the penalties for skipping it are handled differently from ordinary tax penalties.

Who must file an FBAR?

Any “U.S. person” who meets the account and threshold tests must file. A U.S. person includes far more than U.S. citizens living in the United States. It covers:

• U.S. citizens, wherever they live, including citizens who have never lived in the United States.
• U.S. resident aliens, including green-card holders and anyone who meets the substantial-presence test.
• Entities formed under U.S. law, including corporations, partnerships, and limited liability companies.
• U.S. trusts and estates.

If you are a U.S. person under any of these categories and you cross the account and threshold tests below, the filing requirement applies regardless of whether you owe any tax on the accounts.

What counts as a foreign financial account?

The FBAR reaches a broad set of accounts held at a financial institution located outside the United States. The most common reportable accounts are:

• Foreign bank accounts, including checking, savings, and time deposits.
• Foreign securities and brokerage accounts.
• Foreign mutual funds and similar pooled funds.
• Certain foreign retirement or pension accounts, and certain foreign life insurance or annuity policies that have a cash value.

Location is what makes an account “foreign.” An account is foreign if the financial institution is outside the United States, even if the institution is a branch of a U.S. bank, and even if the account holds U.S. dollars. Conversely, a U.S. branch of a foreign bank is generally not a foreign account. The currency in the account and the nationality of the bank are not the test; where the account is maintained is.

The $10,000 threshold is an aggregate, not a per-account number

You must file if the combined highest value of all your foreign accounts exceeds $10,000 at any single moment during the year. This catches people who assume each small account is below the line.

Five accounts holding $3,000 each never individually cross $10,000, but together they total $15,000, so all five are reportable. And it is the highest balance at any point in the year that counts, not the year-end balance, so a large deposit that passed through an account in March can trigger the requirement even if the account was nearly empty by December.

Once you cross the threshold, you report every foreign account you have, including the ones well under $10,000.

Financial interest versus signature authority: both can require a filing

Two different relationships to an account can trigger the FBAR, and the second surprises people constantly.

A financial interest means you are the owner of record or hold legal title, or the account is held by someone acting on your behalf, or through an entity you substantially own. This is the obvious case.

Signature authority means you can control the disposition of the account by direction to the institution, even if you have no ownership stake and none of the money is yours.

A common example is a corporate officer, an employee, or a nonprofit board member who can sign on the organization’s foreign accounts. That person may have to file an FBAR reporting accounts they do not own. Signature authority over a family member’s foreign account, or over a foreign business account, can create the same duty. There are limited exceptions for certain officers and employees, but they are narrow, so do not assume you are covered by one.

When is the FBAR due?

The FBAR is due April 15, with an automatic extension to October 15. You do not need to request the extension; it applies automatically. The FBAR is filed electronically through the BSA E-Filing System, and a spouse can sometimes be included on a single filing, though separate filings are often cleaner. Because the FBAR is separate from your tax return, filing or extending your 1040 has no effect on the FBAR deadline.

How the FBAR differs from Form 8938 (FATCA)

The FBAR is not the only foreign-account filing. Form 8938, the FATCA statement of specified foreign financial assets, is a separate form filed with your tax return, with higher thresholds that start at $50,000 for many taxpayers and rise for those who are married or living abroad. Many people have to file both, reporting the same accounts twice on two different forms to two different parts of the government. We break down the overlap and the different thresholds in FBAR vs. Form 8938: Do You Have to File Both?

What about cryptocurrency on foreign exchanges?

Crypto has its own wrinkle. As the rules stand for the 2026 filing season, an account holding only virtual currency is not currently FBAR-reportable, but most foreign-exchange accounts also hold fiat or cash-like assets, which usually makes the whole account reportable, and the rules are changing. We cover this in detail in Crypto FBAR: Reporting Cryptocurrency on Foreign Exchanges.

What happens if you should have filed and did not?

Missing an FBAR is common and fixable, but the right correction depends on why you missed it. Non-willful taxpayers may be able to use the Delinquent FBAR Procedures or the Streamlined Filing Compliance Procedures, while cases involving possible willfulness point toward the formal IRS Voluntary Disclosure Practice. The penalties for getting this wrong are severe, which we cover in FBAR Penalties: Willful vs. Non-Willful and How to Reduce Them, and the disclosure decision is one to make with an attorney, under privilege, before you file anything. Do not quietly back-file FBARs without advice; a quiet fix can raise more questions than it answers.

How Kugelman Law helps

We advise U.S. taxpayers on foreign-account reporting and represent them in FBAR matters, from determining what is reportable to correcting missed filings and defending penalties. For the full picture of offshore compliance and disclosure options, see our offshore and international tax attorney page.

Our results reflect what disciplined advocacy achieves in high-stakes tax disputes. In one federal matter, two IRS Notices of Deficiency proposing more than $557,000 across six years were settled in U.S. Tax Court down to roughly $38,000, and with avoided interest and California exposure the client effectively saved over $1.2 million. Results depend on specific facts. Past results do not guarantee future outcomes.

Talk to an attorney about your FBAR obligations

If you are unsure whether you have to file an FBAR, or you think you missed one, get a privileged assessment before you act. Schedule a paid, privileged consultation with Kugelman Law by calling (415) 968-1780 or visiting our contact page.

Frequently asked questions

Who has to file an FBAR?

Any U.S. person, meaning U.S. citizens (wherever they live), resident aliens including green-card holders, and U.S. entities, trusts, and estates, who has a financial interest in or signature authority over foreign financial accounts whose combined value exceeds $10,000 at any point during the year. The filing is required whether or not you owe tax on the accounts.

What is the FBAR filing threshold?

You must file if the combined highest balance of all your foreign financial accounts exceeds $10,000 at any single time during the calendar year. It is an aggregate figure across all accounts, and it is based on the highest value during the year, not the year-end balance. Once you cross it, you report every foreign account, including those under $10,000.

Do I have to file an FBAR for an account I don’t own?

Possibly, yes. Signature authority over a foreign account, such as a corporate officer or employee who can direct an employer’s foreign accounts, can trigger an FBAR filing even when none of the money is yours. Limited exceptions exist for certain officers and employees, but they are narrow.

When is the FBAR due?

April 15, with an automatic extension to October 15 that you do not have to request. The FBAR is filed electronically through the BSA E-Filing System and is separate from your tax return, so your 1040 deadline does not affect it.

Is the FBAR the same as Form 8938?

No. They are separate filings with different rules. The FBAR (FinCEN Form 114) is filed with the Treasury’s FinCEN, while Form 8938 is a FATCA form filed with your tax return and has higher thresholds. Many taxpayers must file both. See our comparison for the details.

About the author

Alex Kugelman is the founder and managing attorney of Kugelman Law, with nearly two decades of federal tax controversy experience including U.S. Tax Court and U.S. District Court litigation. He is admitted in California and before the U.S. Supreme Court, the U.S. Tax Court, and the U.S. District Court for the Northern and Eastern Districts of California, and served as San Francisco Chair of the Federal Bar Association Tax Division in 2018. He is nationally recognized for cryptocurrency tax and has been quoted in the Financial Times and the New York Post on California tax enforcement. For matters that reach into IRS offshore examinations, his colleague Otto Bosch, a former IRS Revenue Agent from the Large Business & International division, leads the firm’s federal audit-defense work.

This article is attorney advertising and general information, not legal advice, and it describes rules that can change. Foreign-account reporting is fact-specific. Contacting Kugelman Law does not create an attorney-client relationship.

A $1 million inheritance from a foreign parent that goes unreported can result in a $250,000 IRS penalty, assessed automatically by the system, with the burden squarely on the taxpayer to prove reasonable cause.

At Kugelman Law, we routinely handle Form 3520 penalty matters — including initial examinations, penalty assessments, Appeals conferences, abatement submissions, and post-Farhy litigation strategy. This guide explains when Form 3520 is required, how the penalty works, what has changed after the Farhy v. Commissioner litigation, and how to approach abatement effectively.

What Is Form 3520?

Form 3520 is the Annual Return to Report Transactions with Foreign Trusts and Receipt of Certain Foreign Gifts. It is informational — it does not compute tax — but it is required in several distinct circumstances:

• Receipt of more than $100,000 during the year in gifts or bequests from a nonresident alien individual or foreign estate (with aggregation rules for related donors)
• Receipt of gifts or distributions from foreign corporations or foreign partnerships exceeding the annually adjusted threshold (approximately $19,000 as recently indexed)
• Creation of, or transfers to, a foreign trust by a U.S. person
• Receipt of distributions from a foreign trust
• Ownership of a foreign trust under the grantor trust rules

Form 3520 is due on the same date as your individual income tax return — generally April 15, with available extensions to October 15. The form is filed separately from your Form 1040, mailed to a specific IRS address in Ogden, Utah, which means simple mail-handling errors can become penalty events.

How the Form 3520 Penalty Works

The IRS imposes Form 3520 penalties under IRC § 6039F for foreign gifts and § 6677 for foreign trust matters. The penalty structure differs depending on the violation:

Foreign Gifts and Bequests (IRC § 6039F)

For unreported foreign gifts and bequests, the penalty is 5% of the unreported amount per month that the failure continues, up to a maximum of 25%. For a $1 million inheritance received in 2023 and never reported, the maximum penalty exposure is $250,000.

Foreign Trust Transactions (IRC § 6677)

For failures related to foreign trust transfers, ownership, or distributions, the penalty is the greater of $10,000 or 35% of the gross reportable amount. This penalty can exceed the gift penalty in absolute dollars, and it applies to the U.S. person’s interactions with the trust — including distributions received.

Why the Penalty Is Assessed Automatically

Unlike income tax assessments, Form 3520 penalties are treated by the IRS as “assessable penalties” — meaning the IRS historically took the position that they could be assessed immediately without the pre-assessment deficiency procedures that apply to income tax. When a late-filed or delinquent Form 3520 is processed in Ogden, the penalty is often computer-generated and issued before any human examiner reviews the underlying facts. Taxpayers routinely receive CP15 notices assessing six-figure penalties on transfers that are clearly innocent — a foreign parent gifting cash for a down payment, a foreign grandparent leaving an inheritance, a foreign sibling sending wedding money.

Farhy v. Commissioner and the IRS Assessment-Authority Controversy

In 2023, the U.S. Tax Court in Farhy v. Commissioner, 160 T.C. No. 6, held that the IRS lacked statutory authority to assess penalties under IRC § 6038 for failure to file Form 5471 (a related but distinct foreign information return). The decision cast doubt on the IRS’s assessment authority for a category of international information return penalties that had long been treated as automatic.

In 2024, the D.C. Circuit reversed the Tax Court in Farhy v. Commissioner, 100 F.4th 223 (D.C. Cir. 2024), holding that § 6038 penalties are assessable. The reversal re-established the IRS’s ability to assess these penalties administratively, and the government has taken the position that it applies equally to other international information return penalties. However, the broader legal questions raised during the Farhy litigation — including parallel arguments about § 6039F and § 6677 assessment authority — remain a live issue in other circuits and in ongoing refund litigation.

Practically, this means Form 3520 penalty matters today require careful positioning. Administrative abatement remains the primary path for most clients, but preserving refund claims and litigation options after payment is increasingly important for large penalty assessments. Our firm monitors this area closely and adjusts client strategy as the case law develops.

Reasonable Cause: The Primary Defense

The IRS will abate a Form 3520 penalty where the taxpayer demonstrates reasonable cause for the failure and that the failure was not due to willful neglect. Reasonable cause is a facts-and-circumstances test. In our experience, the most frequently successful reasonable cause arguments involve:

• Reliance on a qualified tax professional who failed to advise of the filing requirement
• Good-faith misunderstanding about whether the transfer qualified as a reportable gift (for example, transfers from a foreign corporation the taxpayer believed was a personal bank account)
• Incapacity, illness, or death in the family affecting the taxpayer’s ability to file
• Ambiguity in the rules themselves — particularly for transfers involving foreign trusts, closely-held foreign entities, or civil-law jurisdictions where the U.S. “trust” concept does not translate cleanly
• First-time filer issues where the taxpayer had no prior knowledge of the U.S. filing system

What reasonable cause is not: “I didn’t know.” Standing alone, lack of knowledge is almost never sufficient. Effective submissions build a factual record supported by declarations, correspondence with advisors, medical records where relevant, and a narrative explaining why the failure was reasonable under the circumstances.

Delinquent Information Return Submission

For taxpayers whose noncompliance has not yet been discovered by the IRS, the Delinquent International Information Return Submission Procedures allow late-filed Forms 3520 to be submitted with a reasonable-cause statement, potentially avoiding penalties entirely. This path is available where the taxpayer has not failed to report associated taxable income — which is the usual posture for foreign gift cases, since the gifts themselves are not taxable.

When Form 3520 Ties to Broader Offshore Issues

Form 3520 rarely sits alone. Taxpayers who receive foreign gifts often also have unreported foreign financial accounts (triggering FBAR and Form 8938 obligations), unreported interests in foreign corporations (Form 5471), unreported passive foreign investment companies (Form 8621), or foreign trust reporting obligations on subsequent years. A proper engagement begins with a full offshore compliance audit so that the Form 3520 issue is not resolved in isolation while other, potentially larger, penalties remain outstanding.

Where broader foreign compliance issues exist, our firm evaluates the full range of voluntary disclosure options — including Streamlined Offshore Procedures, Delinquent FBAR Procedures, and Delinquent Foreign Information Procedures — to design a resolution that addresses every open issue with appropriate penalty protection.

What to Do If You’ve Already Received a Form 3520 Penalty Notice

If you have received a CP15 or similar notice assessing a Form 3520 penalty, several deadlines begin running immediately:

• You have 30 days from the notice to request abatement administratively
• You have 60 days to protest to IRS Appeals after denial of abatement
• After assessment and collection action, you may have rights to Collection Due Process, refund claims after payment, and, in some cases, refund litigation

Do not pay the penalty in full before evaluating your options. Paying first does not waive abatement rights, but it changes the procedural posture of the case in ways that affect strategy. Conversely, do not ignore the notice — collection action on a $250,000 penalty follows quickly if no response is submitted.

How Kugelman Law Handles Form 3520 Penalty Matters

Our process begins with a paid, privileged consultation with Alex Kugelman. We review the penalty notice, the underlying transfer, the Form 3520 as filed (if any), and the client’s broader offshore compliance posture. We develop a reasonable-cause submission, handle all Appeals conferences, and — where abatement is denied or the exposure warrants it — coordinate refund claims and post-payment litigation strategy.

Our firm has handled Form 3520 matters where six-figure penalties were fully abated on reasonable cause grounds, and we have also coordinated broader offshore disclosures that addressed Form 3520 issues alongside FBAR, Form 5471, and Form 8938 exposure. Results depend on specific facts. Past results do not guarantee future outcomes.

Speak with a Foreign Gift Reporting Attorney

Kugelman Law offers paid, privileged consultations with founder Alex Kugelman — fully protected by attorney-client privilege. We do not offer free consultations. We provide boutique, white-glove representation in Form 3520, FBAR, and offshore information return matters.

Call (415) 968-1780 or schedule your consultation here. Representation provided throughout California and nationwide.

Frequently Asked Questions About Form 3520 Penalties

Is a foreign gift taxable?

Generally no. The IRS does not tax the recipient of a gift from a foreign person — but the reporting obligation on Form 3520 is separate from taxability, and failure to report triggers the penalty even though the underlying gift is tax-free.

What is the threshold for reporting a foreign gift on Form 3520?

For gifts from a nonresident alien individual or foreign estate, the threshold is more than $100,000 in aggregate during the year. For gifts from foreign corporations or partnerships, the threshold is considerably lower and is indexed annually.

What is the maximum Form 3520 penalty?

For unreported foreign gifts under IRC § 6039F, the maximum is 25% of the unreported amount. For foreign trust matters under IRC § 6677, the penalty can reach 35% of the gross reportable amount.

Can the IRS really impose a $250,000 penalty on a $1 million inheritance?

Yes — and it does, routinely. The penalty is automated in many cases and is assessed before any examiner reviews the underlying facts. Reasonable cause abatement is the primary defense.

Does Farhy v. Commissioner eliminate Form 3520 penalties?

No. The D.C. Circuit reversed the Tax Court in Farhy in 2024, restoring IRS assessment authority for § 6038 penalties. The broader assessment-authority arguments remain live in other contexts and circuits, but Farhy alone does not eliminate Form 3520 liability or provide automatic abatement.

How do I request abatement of a Form 3520 penalty?

By submitting a written reasonable-cause statement to the IRS within 30 days of the penalty notice, supported by documentation and, where appropriate, sworn declarations. If abatement is denied, the matter can be protested to IRS Appeals.

What if I also have unreported foreign accounts or other foreign information returns?

The Form 3520 issue should be addressed as part of a broader offshore compliance review. Our firm coordinates Streamlined Offshore Procedures, Delinquent FBAR Procedures, and Delinquent Foreign Information Procedures to resolve multiple foreign reporting issues in a single integrated strategy.

Does Kugelman Law offer free consultations for Form 3520 matters?

No. We offer paid, privileged consultations with Alex Kugelman that are fully protected by attorney-client privilege — which is particularly important in offshore matters where willfulness and criminal exposure are sometimes at issue.

About the Author: Alex Kugelman

Alex Kugelman is the founder and managing attorney of Kugelman Law, a boutique tax controversy and cryptocurrency tax firm serving clients throughout California and nationwide. Admitted to the California Bar in 2008 (No. 255463) and the U.S. Supreme Court, Alex has nearly two decades of federal tax controversy experience, including litigation in U.S. Tax Court and U.S. District Court. He served as San Francisco Chair of the Federal Bar Association’s Tax Division in 2018 and is a member of the Marin County Assessment Appeals Board. He is a nationally recognized cryptocurrency tax authority, featured on the Bitcoin.tax podcast and The Mark Milton Show. J.D., Chapman University Fowler School of Law (2007); B.A., University of Colorado at Boulder (2001). Read Alex’s full bio.