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FBAR Deadline is June 28, 2013
This month we remind taxpayers of the upcoming June 30, 2013 deadline for filing Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), to report financial interests…
FBAR Deadline Slightly Extended
After a misworded posting caused confusion about the 2020 deadline to file FBARs (i.e., FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)), Treasury’s Financial Crimes Enforcement Network…
Caution: Increased FBAR Enforcement
…FBAR filing requirement and the government’s vigilant enforcement. The IRS has in its arsenal many ways to find out about Americans’ bank and or investment accounts they may have, how…
FBAR statute of limitations court case ruling
…Bank Account Reporting, or FBAR forms from 2006 through 2008. The court held that the Internal Revenue Service could not go back beyond the general three-year limitations period. FBAR requirements…
Top FBAR Reporting Error
The most common FBAR reporting mistake is simply failing to file. Some U.S. persons continue to deliberately conceal assets in secret offshore bank accounts in the hope of evading U.S….
Willful FBAR Penalties
U.S. Citizens who have a financial interest in or signature authority over foreign bank accounts that hold an aggregate amount greater than $10,000 are required to report the accounts to…
How to Defend Against FBAR Penalties
…taxpayers who are not in compliance—from the offshore voluntary compliance submissions submitted (which often leads to other taxpayers and advisors thereto) and from banks such as UBS and HSBC who…
High Penalties for failure to file an FBAR: Not Really Enforced (yet)?
U.S. persons, including U.S. citizens, residents, corporations and estates, must report certain foreign financial accounts, including bank accounts, brokerage accounts and saving accounts to the U.S. Treasury department each year….
The Strange Case of U.S. v. Hughes: Willful and Non-Willful (at the Same Time?)
…Limited which was solely owned by Hughes. Ms. Hughes had a financial interest in, and signature authority over the two entities’ bank accounts for the following years. Hughes had to…
New FBAR Deadline applies to 2016 Tax Year Onwards
…Bank and Financial Accounts (FinCEN Form 114) (the FBAR) for 2016 and future years. The FBAR must be filed by a U.S. person (i.e., an individual who is a U.S….
Watch Out: IRS Audits of ERC Claims Expected
…credit if they significantly reduced revenue or operational restrictions. To prove that you qualified based on revenue, you must provide sales statements, profit and loss reports, bank statements, or other…
More Tax Complexity: New Form 8938
…taxpayers with foreign accounts and assets. FATCA created Form 8938, an additional foreign account reporting requirement over and above the Report of Foreign Bank and Financial Accounts (FBAR) or Form…
No Springing in Spring
…physicians have made the correct diagnosis. Some banks have also been known to refuse to accept POAs unless they are on the bank’s own forms. You can avoid all of…
Problems with Joint Tenancy Property
…tenant to the others. There is no need for a formal probate (unless all the joint tenants die). Convenience: Bank accounts held in joint tenancy can be withdrawn by any…
Beware PODs and TODs
Virtually any bank or brokerage account can provide that it is paid on death (“POD”) or transferred on death (“TOD”) to named beneficiaries. And IRAs, 401Ks, pension plans and insurance…
IRS Listens, and Postpones Increased Form 1099 Reporting for PayPal and Venmo
…not subject to any 1099 reporting because it is a bank-to-bank service that does not hold funds. We suggest creating a separate personal and business profile/account to keep business transactions…
The IRS Large Business and International division (LB&I) has announced a new Offshore Private Banking enforcement campaign
…offshore bank accounts, as a result, they suggested the campaign. The IRS Offshore Private Banking enforcement campaign goal is to improve return selection, identify issues representing a risk of non-compliance,…
Beware IRS Letter 6291
…Via FATCA and subpoenaed bank records, the IRS is in possession of records that identify taxpayers with transactions or accounts at offshore private banks. Soft letters are IRS correspondence to…
Finally: IRS Reminds Those with Foreign Assets of U.S. Tax Obligations
…citizens and resident aliens to report any worldwide income, including income from foreign trusts and foreign bank and securities accounts. In most cases, affected taxpayers need to fill out and…
India and US signed FATCA Agreement Today
…Swiss, Israeli and Indian banks, India continues to be a focal point for the U.S. government. While new criminal prosecutions start and continue, our law firm expects unabated aggressive enforcement…
Individuals with disabilities can create their own self-settled trusts
…individual with disabilities. Unlike self-settled SNTs, assets held by third-party SNTs don’t have to be used to repay the Medicaid program for the cost of care provided to the individual…
New Law’s Reporting Requirements Make It Very Likely That the IRS Will Now Know About Your Foreign Account
Under the recently enacted Foreign Account Tax Compliance Act (“FATCA”), foreign financial institutions (“Financial institutions” is broadly defined to include banks, mutual funds, funds of funds, exchange-traded funds, hedge funds,…
Navigating Foreign Waters: The Complex Requirements of Foreign Accounts Compliance
…Program for noncompliant taxpayers. Qualifies as 3 taxation credits. The Academy of Continuing Professional Education (ACPE) has proudly offered continuing education courses for accountants over the past 22 years. During…
Tax Relief for Strategic Investments
…and was under-utilized. The law went into effect immediately and shall apply to tax periods beginning on or after January 1, 2012. The program applies to several industries including, but…
Quiet or Silent Disclosure Commentary from the Government Accountability Office
… Despite the significant risks of not coming forward through one of IRS’s offshore programs, some taxpayers decide to do nothing and remain noncompliant. Other taxpayers have attempted to disclose…
New Taxpayer Advocate Service Report Discusses Optouts out of the OVDI/OVDP
…to conclude. In previous TAS reports, TAS reported that the average penalty for 2009 optouts was about $15,000 with zero criminal prosecutions. For the 2011 program, there have been 323…
IRS announces an update to its Voluntary Disclosure Practice Preclearance Request and Application
…Criminal Investigation Voluntary Disclosure Practice IRM 9.5.11, Investigative Process – Other Investigations IRM 4.63.3, Withholding and International Individual Compliance – Offshore Voluntary Disclosure Program, Streamlined Filing Compliance Procedures and Voluntary…
2011 Offshore Voluntary Disclosure Initiative Frequently Asked Questions (FAQs) and Answers
…the prior program which saw disclosures spread to agents and field offices across the country, as well as re-assignments and transfer to new agents midway through the process. The first…
Finally. Government Accountability Office makes recommendations to the IRS for tax laws education to immigrants
…[GAO], recognize that multiple outreach efforts could help to draw additional taxpayers into the offshore programs, and that data mining information from the program applications can help identify these groups….
IRS Clarifies Requirements for Streamlined Filing Procedures
…Our firm recently presented a informational webinar on the Streamlined Filing Compliance Procedures and the Offshore Voluntary Disclosure Program. Materials from the webinar can be downloaded here: Game Changer Streamline….