Upcoming live video webinar: “FBAR and U.S. Tax Reporting: Compliance Requirements for Foreign Assets”

I am pleased to announce that I will be speaking in an upcoming Strafford live video webinar, “FBAR and U.S. Tax Reporting: Compliance Requirements for Foreign Assets” scheduled for Wednesday, March 16, 1:00pm-2:30pm EDT.  The IRS has continually reaffirmed its commitment to

Small PFIC Exception to Filing Form 8621

The Form 8621 filing requirements for shareholders of a passive foreign investment company (PFIC) are in effect for the current tax season. The annual filing requirement is imposed on U.S. persons who are PFIC shareholders who do not currently file

Penalty relief for International Information Forms 5471, 5472, and 8865

US tax law imposes large penalties for the failure to timely file international information returns on Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations; Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign

A Lesson From Brown v. U.S.: A Defective Tax Refund Filing

The recent case from the U.S. Court of Appeals for the Federal Circuit in Brown v. the U.S. shows the detriments to Taxpayers who do not properly file their returns with the IRS in order to receive their tax refunds. 

The Strange Case of U.S. v. Hughes: Willful and Non-Willful (at the Same Time?)

A recent decision from the District Court of Northern California has created more questions in the tax community about FBAR penalties. Usually, in challenging FBAR penalties, courts conclude that the US taxpayer will pay willful FBAR penalties, non-willful FBAR penalties,

How to Avoid Criminal Prosecution Through Voluntary Disclosure

The Voluntary Disclosure Practice is an IRS-created option of the IRS Criminal Investigations for U.S. Taxpayers at risk for criminal prosecution due to a tax-related offense. Taxpayers who have willfully failed to submit tax information reports may willingly submit a

All the Many FBAR Late Filing Procedures

The FBAR or Foreign Bank and Financial Account Reporting or FinCen Form 114 is a form which many U.S. taxpayers are unaware and unfamiliar with and thus many of them become noncompliant and delinquent. However there are a number of