Search Results for: fatca
IRS Collects $10 Billion From Voluntary Disclosures of Foreign Assets
…Compliance Act, or FATCA, as part of the HIRE Act. The legislation requires foreign financial institutions to report on the holdings of U.S. customers or else face stiff penalties of…
IRS Announces New Investigative Units
…leads from information received through the Swiss Banking Program, the Foreign Account Tax Compliance Act (FATCA) and the Panama Papers investigation, among other sources. The effort is also clearly intended…
Offshore Compliance Programs Generate $8 Billion; IRS Urges People to Take Advantage of Voluntary Disclosure Programs
…including the offshore program and streamlined procedures, to come back into full compliance with their tax obligations.” Under the Foreign Account Tax Compliance Act (FATCA) and the network of intergovernmental…
Bank Leumi: Another Foreign Bank Recommends the IRS Voluntary Disclosure Program
…to the U.S. government after admitting to similar wrongdoing with its private bank. The bank provided more than 4,400 names of U.S. account holders to U.S. authorities. FATCA requires foreign…
Caution: Foreign Businesses Require Additional Reporting
…may find that their U.S. connection brings unwanted U.S. reporting requirements and scrutiny. Aside from the CFC rules discussed above, the new FATCA (Foreign Account Tax Compliance Act) requires ownership…
The IRS Large Business and International division (LB&I) has announced a new Post OVDP Compliance enforcement campaign
…Foreign Account Tax Compliance Act (FATCA), the IRS announced a new amnesty program to take the place of the 2009 program; the official title was the 2011 Offshore Voluntary Disclosure…
Benefits and consequences of entering or failing to enter the Offshore Voluntary Disclosure Initiative program
…Involuntary Discovery as a result of FATCA and Mutual Information Sharing Treaties Criminal Prosecution Lengthy comprehensive audit examination of tax returns 1-5 years’ jail sentence (based on magnitude of un-reporting)…
2 recent IRS developments that will impact Indian Americans
…FATCA (Foreign Account Tax Compliance Act) now almost imminent, the IRS is soon going to get more details about foreign financial accounts. Most experts agree that there is going to…
ABA COMMENTS ON THE 2014 OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS
…(“FATCA”). Indeed, one of the criteria for identifying potential U.S. persons under the FATCA regulations and the Intergovernmental Agreements is whether the person was born in the United States. …
Do You Have to Pay US Taxes on Foreign Inheritance?
…there are important legal considerations to review, including the Foreign Account Tax Compliance Act (FATCA), which directly deals with foreign compliance matters. This article summarizes international estate planning and tax…
Run to the Door: IRS Terminates Offshore Voluntary Disclosure Program (OVDP) effective September 28, 2018
…Act (FATCA) and the ongoing efforts of the IRS and the Department of Justice to ensure compliance by those with U.S. tax obligations have raised awareness of U.S. tax and…
IRS Releases New IRS Form W8-BEN: U.S. persons beware of completing such form at the request of a third party
…been driven by the changes in the law under FATCA. The new IRS Form W-8BEN and its instructions are accessible here. Importantly, no U.S. citizen can legally sign and certify…
2020 New Year’s Tax Planning Resolutions: Resolve To Plan Better
…targeted taxpayers who may have foreign accounts (remember FATCA). Failure to report foreign accounts, or reporting them incorrectly, can have serious consequences, including high civil and criminal penalties. Since these…
How to Defend Against FBAR Penalties
…pursuant to Deferred Prosecution Agreements) and using recent FATCA legislation, which starting this year will force many foreign banks to disclose their U.S. account holders or be subject to a…
New Unreported Offshore Assets case: Bad facts leads to bad results
…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,…
Internal Revenue Service again issues annual reminder to US persons to report foreign accounts and foreign income
…first year of the form. Form 8938 resulted from the Foreign Account Tax Compliance Act, known as “FATCA.” The filing thresholds are much higher for this form than for the…
A solution in a tough tax season: the IRS Streamlined Offshore Procedures
…the risk/reward for each taxpayer. Regardless, as FATCA continues to go fully online (and the cooperating bank list grows), the cost and risk of doing nothing has gone up exponentially….
Solution: Streamlined Domestic Offshore Procedures
…as FATCA continues to go fully online (and the cooperating bank list grows), the cost and risk of doing nothing has gone up exponentially. In summary, taxpayers with undisclosed offshore…
IRS expands use of Subpeonas
…the banks’ clients who came clean and disclosed their previously undeclared offshore accounts. With new data expected from the FATCA initiative, which forces financial institutions worldwide to report U.S. taxpayer…
Avoiding and Defining Willfulness
…not disclose such offshore accounts and assets. In addition, many U.S. taxpayers, both domestic and international, are facing pressure from foreign banks to disclose their U.S. taxpayer status (via FATCA…
New Form Updates for Foreign Accounts
…obtain an employer identification number. All of the above forms are related to taxpayers’ compliance with foreign accounts, which is under great scrutiny after passage of the US FATCA law….
Information Sharing of Account Holder Information Officially Begins
The IRS has begun receiving information regarding tax year 2014 from nations around the world who have agreed to comply with FATCA. Some of those countries negotiated reciprocal agreements to…
New IRS guidance Announced for IRS Streamlined Offshore Procedures.
…Regardless, as FATCA continues to go fully online (and the cooperating bank list grows), the cost and risk of doing nothing has gone up exponentially. In summary, taxpayers with undisclosed…
New offshore voluntary disclosure program (OVDP) changes expected to be favorable to taxpayers
…modifications. Koskinen predicted that more details about the OVDP are expected to be available in coming weeks as the July 1 FATCA implementation date approaches. So stay tuned. In the…
The Dreaded IRS Letter 6185: “We received information that you have a foreign account”
…income tax and information reporting requirements associated with these foreign activities, otherwise, they are subject to penalties and possible criminal prosecution. Via FATCA and subpoenaed bank records, the IRS is…
Protective Filing of Information Returns
…30, with no extension possible. A U.S. person with an ownership interest in foreign accounts may also need to file a Form 8938. This form, also known as the Fatca…
Beware of Overlooked Common Overseas Tax Forms
…on June 30, with no extension possible. Form 8938: This form, also known as the FATCA form, is used to report Specified Foreign Financial Assets and the income derived from…
Watch Out for PFIC Status
…be used to offset capital gains on other investments. Due to the Foreign Account Tax Compliance Act (FATCA), which forces every single financial institution to submit information on their American…
The IRS Large Business and International division (LB&I) has announced a new Offshore Private Banking enforcement campaign
…activities, otherwise, they are subject to penalties and possible criminal prosecution. Via FATCA and subpoenaed bank records, the IRS is in possession of records that identify taxpayers with transactions or…
All the Many FBAR Late Filing Procedures
…a U.S. taxpayer may choose to pay a 5% Title 26 Miscellaneous Offshore Penalty instead of other delinquent FBAR and FATCA penalties. Our firm has successfully filed more than 300…