NY Art Consultant Indicted for Filing False Tax Returns and Failing to File FBARs

- By : P. Patel

…account report (FBARs). Doyle was arrested in New York. In 2003, Ms. Doyle’s father died and left an inheritance of over $4 million to Doyle. Doyle, who was appointed the…

Avoiding and Defining Willfulness

- By : P. Patel

…to his FBAR reporting obligations, which would mean that he qualifies for the streamlined programs. In short, the recent guidance on willfulness in the FBAR context may create as many…

2 recent IRS developments that will impact Indian Americans

- By : P. Patel

…tax return with the IRSwhere he failed to report the interest income earned on bank deposits at HSBC India. Second, he did not file an FBAR (Foreign Bank and Financial…

Received a FATCA Letter from Your Foreign Bank?

- By : P. Patel

…are the potential consequences of FBAR non-compliance or other tax problems? If a US taxpayer has failed to comply with his or her FATCA, FBAR, or other income tax reporting…

Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Foreign Offshore Procedures (SFOP)

- By : P. Patel

…to submit, in addition to filing any delinquent FBARs for each of the most recent six years for which the FBAR due date has passed: (1) delinquent or amended or…

Beware of FATCA Letters

- By : P. Patel

…of any bank account. Filing FBAR and Form 8938 If accountholder receiving the FATCA letter has not already cleaned up their accounts and properly reported any foreign accounts to the…

Analysis: IRS New Disclosure Program

- By : P. Patel

…may do so, but must present evidence to support their requests. The penalty with respect to Foreign Bank Account Reports (“FBAR”) has also been changed under the new procedures. In…

2011 Offshore Voluntary Disclosure Initiative (OVDI)

- By : P. Patel

…90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), should not use the OVDI, but rather are advised by the IRS to just file the delinquent FBAR reports and attach…

National Taxpayer Advocate Identifies OVDP Program as a Serious Problem

- By : P. Patel

…taxpayers from voluntarily correcting FBAR violations outside of the OVD programs. Those who opted out could be subject to an examination and FBAR penalties of up to 300 percent of…

Latest Guilty Plea for an Another HSBC Offshore Bank Accountholder

- By : P. Patel

…Financial Accounts, Form TD F 90-22.1 (the FBAR). The FBAR for the applicable year is due by June 30 of the following year. Shiavo appears to have tried to make…

Extension of the OVDI Deadline of August 31, 2011

- By : P. Patel

…include properly completed and signed agreements to extend the statute to assess tax (including tax penalties) and to assess FBAR penalties. Written extension requests must include a list of the…

For Tax Professionals: A Guide to the IRS’s Voluntary Disclosure Practice

- By : P. Patel

…is not designed to address the IRS’s discretion whether to impose civil tax or FBAR penalties. The Internal Revenue Manual states that a voluntary disclosure made by a taxpayer will…

Beware of Overlooked Common Overseas Tax Forms

- By : P. Patel

…those with children eligible for the additional child tax credit and those interested in contributing to U.S. retirement plans (traditional and Roth IRAs, SEPs, solo 401(k)s, etc.) FBAR Form FinCEN…

Protective Filing of Information Returns

- By : P. Patel

…such as a Form 5471, to disclose that ownership. A U.S. person with an ownership interest in a foreign account may need to file a FBAR Form FinCEN 114. This…

Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Domestic Offshore Procedures (SDOP)

- By : P. Patel

…in the streamlined procedures is to ascertain whether the taxpayer’s compliance failure, including the failure to file an FBAR, was actually non-willful. The IRS has defined “nonwillful conduct” as “conduct…

New Form Updates for Foreign Accounts

- By : P. Patel

…States person that has a financial interest or signature authority over foreign financial accounts must file FinCEN Form 114 (commonly referred to as the “FBAR”) if the aggregate value of…

IRS Updated Voluntary Disclosure Practice is a Game-Changer

- By : P. Patel

…accuracy-related penalty. The FBAR penalty has also been changed under the new procedures whereby the IRS will assert willful FBAR penalties. In most cases a penalty for a willful FBAR

American Citizens Abroad (ACA) writes letter to IRS Commissioner regarding unfair offshore asset treatment

- By : P. Patel

…forward under the OVDP have overseas addresses and how much of the US$ 4.4 billion collected under the program comes from FBAR fines instead of back taxes. Unfortunately, our law…

IRS reminds those with foreign assets about U.S. tax obligations

- By : P. Patel

…missing the April 17 deadline an automatic extension until Oct. 15, 2018, to file the FBAR. Specific extension requests are not required. In the past, the FBAR deadline was June…

A solution in a tough tax season: the IRS Streamlined Offshore Procedures

- By : P. Patel

…and may have also failed to file a FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR) (previously Form TD F 90-22.1) and/or one or more international information…

Reasons to Opt Out of the 2011 OVDI Program

- By : P. Patel

FBAR penalty assessed against those opting out of the 2009 OVDP is only $15,737.19 on average. This average is according to the IRS’ response to TAS information request (Oct. 23,…

IRS Offshore Voluntary Disclosure Programs Continue to Burden “Benign Actors” and Damage IRS Credibility

- By : P. Patel

…F 90–22 .1, Report of Foreign Bank and Financial Accounts (FBAR)) . As described in prior reports, these programs apply a one-size fits-all approach designed for “bad actors” to “benign…

IRS Announces New Clarifying FAQs for Streamlined Offshore Compliance Program

- By : P. Patel

…each of the most recent six years for which the FBAR due date has passed, file any delinquent FBARs. Under the streamlined offshore procedure for U.S. residents, the taxpayer must…

FATCAts

- By : P. Patel

…comply with these obligations. To combat this perceived non-compliance, FATCA joins the existing FBAR reporting, recently enacted ‘foreign financial asset’ reporting, the 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI), which…

“Willfulness” When Deciding Whether to Opt Out of 2011 OVDI

- By : P. Patel

…the OVDI, but feel that their failure to file the FBAR form on an annual basis was “non-will”, may considering opting out. Who makes the determination as to willfulness and…

To Opt Out or Not Opt Out: That is the Question

- By : P. Patel

…in the OVDI/OVDP program because he or she does not want to guarantee penalty imposition. Instead, the taxpayer will just file their delinquent FBARs and amended (or original) U.S. tax…

Vatican Signs FATCA Agreement

- By : P. Patel

…and Foreign Bank Account Reports (FBAR) to report foreign accounts and assets. With such comprehensive databases, noncompliant taxpayers should beware; the government has better and more complete information than ever….

File a Protective Claim for Refund for Possible OVDP Opt Out Cases

- By : P. Patel

…well versed in the significant distinctions between the FBAR and income tax assessment statutes. The statute of limitations for assessment of FBAR penalties is governed by Title 31 of the…

New Unreported Offshore Assets case: Bad facts leads to bad results

- By : P. Patel

…than $10,000, by filing a FBAR, or Foreign Bank Account Report. Enforcement of this law increased after the signing into law of the Foreign Account Tax Compliance Act, or FATCA,…

Common Issues for US-India Tax Reporting

- By : P. Patel

…the world. If you are a visa holder the rules are a bit more complicated about when universal taxing jurisdiction is triggered. FBAR Information: The FBAR is a reporting form…

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