Live Webinar on U.S.-India Tax Planning: Key Issues, Tax Treaties: Limited Free Registrations Available

…and India for certain taxpayers India’s Forms ITR Taxable income, reportable accounts, and FBAR/FATCA filings U.S. reporting requirements of India-sourced investments Foreign tax credit considering the fiscal year ITR Key…

New IRS Website for New Immigrants to the United States: Key Tax Responsibilities

(FBAR) If you have foreign bank accounts with an aggregate balance exceeding $10,000 at any point during the year, you are required to file the Report of Foreign Bank and…

National Taxpayer Advocate calls IRS Penalties Draconian and Inefficient

…the burden to establish willfulness by clear and convincing evidence before asserting a civil willful Report of Foreign Bank and Financial Accounts (FBAR) penalty and that the government cannot meet…

Interesting 2023 Foreign Account Cases

Foreign Account/FBAR confusion: In Kurotaki v. United States, 132 AFTR2d 2023-6138, a Hawaii federal district court determined that a U.S. green card holder who lived in Japan and spoke no…

IRS FBAR Penalties Are Now Unmitigated

The Internal Revenue Service will no longer reduce the penalty for taxpayers who non willfully fail to file Reports of Foreign Bank and Financial Accounts (FBAR or FinCen 114), according…

REPORTING FOREIGN ASSETS & ACTIVITIES: REQUIREMENTS AND CHALLENGES: Complimentary CPE Presentation

FBAR penalties Summary of most common international tax reporting forms RSVP: https://www.wgcpas.com/reporting-foreign-assets-activities-requirements-and-challenges/ CPE: 1.5 NJ credits WHEN: Monday, April 24th, 2023 Networking & Snacks: 6:00-6:30 PM CPE Seminar: 6:30-8:00 PM…

Foreign Gift Received: Form 3520 Penalties Eliminated in New Court Case

…determined that the IRS could only penalize taxpayers once per-form (instead of per-account) per-year for failing to file a Report of Foreign Bank and Financial Accounts (or “FBAR”). The Wrzesinski…

Rare Supreme Court Ruling Favors Taxpayers!

FBAR. The statute (31 U.S.C. §5321(a)(5)(B)) prescribes a civil penalty of up to $10,000 for a non-willful violation of any provision of the FBAR filing requirement (unless due to reasonable…

High Penalties for failure to file an FBAR: Not Really Enforced (yet)?

…If the aggregate value of the foreign financial accounts exceeded $10,000 at any time during the year, a ‘Foreign Bank Account Report’ (FBAR) must be filed. The FBAR is due…

New IRS FBAR Practice Unit

…for Late-Filed FBARs? Under the BSA, the IRS can assess civil penalties if a USP has an FBAR reporting obligation and fails to timely file a complete and accurate FBAR. …

Recent Court Decision Shows Risks of IRS Streamlined Filing Compliance Procedures

…v. U.S., No. 21-1202T (Fed. Cl. Aug. 23, 2022). In Flint, the taxpayer failed to file FBARs regarding significant holdings in foreign accounts. After the taxpayer’s husband passed away, the…

Foreign pension accounts reporting on the FBAR

…reported on FBAR? Some practitioners take the position that these plans do not need to be reported on the FBAR.  We disagree. A conservative approach would be to report it…