June 2015 – Tax, Estate Planning & Probate Law Center

Penalties for Form 5472 Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business

28 Jun 15

We would like to highlight a recent change in the IRS’ policy with respect assessing statutory late filing penalties related to certain international information forms. Of particular concern to international businesses is the revised policy that the $10,000 penalty may

Vatican Signs FATCA Agreement

28 Jun 15

Praying may not be enough for non-compliant taxpayers (or evaders) under the Foreign Account Tax Compliance Act (FATCA). The Vatican has become the latest FATCA signatory to share bank information with the US. The Vatican has signed an agreement with

Top 4 Exceptions to FBAR Filing Requirement

27 Jun 15

FBARs are due this week (again). Below are the top 4 exceptions we often see for the FBAR filing requirement. Certain Accounts Jointly Owned by Spouses – the spouse of an individual who files an FBAR is not required to

Received a FATCA Letter from Your Foreign Bank?

24 Jun 15

If you have any US connections and have a non-U.S. bank account, you may have recently received a letter from your bank asking for your tax information. This may seem odd or new to you but lately banks everywhere want

BE-10 Report: A New Overlooked International Reporting Form

21 Jun 15

The Bureau of Economic Analysis (BEA) is an agency of the U.S. Department of Commerce and is currently conducting a benchmark BE-10 survey which entails the filing of a BE-10 report by any U.S. person that directly or indirectly owned

Educational Panel Discussion: The U.S. Government’s Global Crackdown on Tax Evasion: Where It Has Been and Where It Is Going

19 Jun 15

Last we spoke at a SABANA tax section bar association educational panel “The U.S. Government’s Global Crackdown on Tax Evasion: Where It Has Been and Where It Is Going” for attorneys in Orlando FL. Fellow panelists included Nanette Davis (US

Beware: IRS Reminds Taxpayers of FBAR Deadline

19 Jun 15

Last week, the Internal Revenue Service reminded all taxpayers with a filing requirement for a foreign bank account report to report their foreign assets by the June 30 deadline. The IRS has been targeting FBAR compliance over the last several

New IRS Guidelines for Willful FBAR violations

06 Jun 15

Last week, the Internal Revenue Service released interim guidance (SBSE-04-0515-0025) on foreign bank account report (FBAR) penalties to improve the administration of the FBAR compliance program. The guidance contains amendments to the Internal Revenue Manual (IRM), effective immediately, and applies to