The debate over FBAR penalties for non-willful failure to disclose all of an individual’s or business’ foreign bank accounts has reached the Supreme Court. The issue is whether the maximum $10,000 Foreign Bank Account Reporting
On its website, the IRS has announced that it has retired its Form 3520/3520A compliance campaign. In welcome relief for taxpayers, the IRS also indicates in updated IRM procedures that it will assert only one penalty
The Internal Revenue Service today wrapped up its annual “Dirty Dozen” scams list for the 2022 filing season, with a warning to taxpayers to avoid being misled into using bogus tax avoidance strategies. The IRS
Nearly $3.5 million estimated tax loss over four years A tax preparer was recently sentenced in U.S. District Court in Seattle, to a year and a day in prison for 14 counts of aiding and
Event Details May 9, 2022 3:00 pm to 4:00 pm Many investors unknowingly invest in Passive Foreign Investment Companies (PFICs) and as a result must file IRS Form 8621, Information Return by a Shareholder of a
I am pleased to announce that I will be speaking in an upcoming Strafford live video webinar, “Resolving International Tax Compliance Disputes: FBAR Controversy, Penalties, Appeals, Form 3520/3520-A, Form 5471” scheduled for Wednesday, May 11, 2022 1:00pm-2:30pm
Paying taxes twice on the same income is a concern most U.S. citizens have if they earn income abroad. Luckily, the U.S. has entered into tax treaties with many countries to help alleviate that concern.
We receive many client queries regarding FBAR and Form 8938. If you are a U.S. person and you have assets and accounts in a foreign country, you may need to submit Form 8938 and/or FinCEN
Certain US persons may become subject to the passive foreign investment company (PFIC) regime if they own an interest in a foreign corporation that invests primarily in passive investments (or become US persons while owning
A PFIC is a passive foreign investment company. One of the most common types of PFIC is ownership of a foreign mutual fund. Our office has worked with clients from dozens of countries. However, Indian
The IRS released its new 2022 FBAR Fact Sheet last month, which comprehensively provides all information related to the FinCEN FBAR Form 114. Interestingly, it fails to include the Delinquent FBAR Submission Procedure (or DFSP),
We have had many clients with British retirement accounts and pensions, which often cause US tax complications. Self-invested personal pensions (SIPP) can be a complex account for US tax purposes. A straightforward pension for a
