Search Results for: fbar
FBARs from Wuhan
…required to report any foreign bank accounts that hold more than $10,000 in total at any time by annually filing an FBAR. Lieber allegedly failed to file FBARs for the…
IRS posts its “wins” involving offshore accounts
…failing to file a Report of Foreign Bank and Financial Accounts (FBAR) form and failing to disclose his UBS bank account. Oct. 3, 2014 — Howard Bloomberg pleaded guilty to…
Permanent annual automatic extensions granted for FBARs to October 15
The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced last week that, to implement the new due date for FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR),…
The Strange Case of U.S. v. Hughes: Willful and Non-Willful (at the Same Time?)
…US taxpayer will pay willful FBAR penalties, non-willful FBAR penalties, or no FBAR penalties. U.S. v. Hughes is a strange case however because the court held that the taxpayer was…
ABA COMMENTS ON THE 2014 OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS
…income tax filing obligations and FBAR filing obligations with respect to foreign financial accounts worth more than $10,000. Yet according to published reports, only 807,000 FBARs were filed in 2012…
Financial Crimes Enforcement Network (FINCEN) Issue Final Rules
…a period of five years. The FBAR has become a difficult and comprehensive reporting requirement for individuals with foreign accounts. The penalties for failuer to file an FBAR are extrememly…
New Streamlined Domestic Offshore Procedures (SDOP) is a Game Changer
…5472, 8938, 926, and 8621), (2) for each of the most recent 6 years for which the FBAR due date has passed (the “covered FBAR period”), file any delinquent FBARs…
Numerous Criminal Prosecutions of Taxpayers with Unreported Offshore Accounts
…one count of willful failure to file an FBAR under 31 U.S.C. §§ 5314 and 5322. Abrahamsen admitted that he willfully failed to file a foreign bank account report and…
The Risks of “Opting Out” of OVDI
…FBAR be brought as a civil case in the United States District Court, rather than under the assessment provision of the Code. The IRS in its FBAR Frequently Ask Questions…
Method to Cure Delinquent or Incomplete Foreign Information Returns Without Penalties
…for failure to file the FBAR, when the taxpayer has properly reported—and paid tax on—all taxable income, but only recently learned that it was subject to the FBAR reporting requirement….
Streamlined Procedures for U.S. Taxpayers Residing In the United States
…all required information returns; for each of the most recent six years for which the FBAR due date has passed (the “covered FBAR period”), file any delinquent FBARs; pay a…
IRS Reminds (again) Taxpayers to Report Foreign Income and Assets
…(FinCEN) Form 114 (“FBAR.”) Remember there are also other obligations on tax forms to disclose foreign holdings. A few important things to consider when filing and FBAR: a) All FBAR…
Explore the OVDI opt-out option: Argue for Penalty Mitigation
…of the voluntary disclosure initiative and allow us to demonstrate the absence of willfulness and avoid the normal FBAR penalty regime. We have been aggressively pursuing OVDI opt-outs for some…
More Tax Complexity: New Form 8938
…of limitation rules apply. Form 8938 is separate from the FBAR form and its requirements. The FBAR (90-22.1) is filed with the US treasury while Form 8938 is filed with…
IRS Reminds U.S. citizens and dual citizens about U.S. filing requirements
…have only recently learned about their obligation to file U.S. income tax returns or FBARs, the IRS said in the fact sheet. Generally, FBAR must be filed by U.S. persons…
The “Quiet” or “Silent” Disclosure
…original filed return). The filing of a delinquent FBAR also has heighted audit risk (probably significantly greater than a timely filed FBAR). Also there are other factors. For no FBAR…
Full Analysis of Updated 2012 OVDP Program
…use the voluntary disclosure process. Rather, they should file the delinquent FBAR reports according to the FBAR instructions (send to Department of Treasury, Post Office Box 32621, Detroit, MI 48232-0621)…
New IRS Disclosure Program Announced for Non-Resident Taxpayers: Streamlined Foreign Offshore Procedures
…procedures. For each of the most recent 6 years for which the FBAR due date has passed, file delinquent FBARs according to the FBAR instructions and include a statement explaining…
2018 ABA COMMENTS ON THE OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS
…of Foreign Bank and Financial Accounts) (“FBARs”). We are mindful that the burden estimates for the collection of information often do not reflect the actual burden imposed, but make the…
Beware of U.S. tax consequences to a foreign trust with a U.S. beneficiary
…and an interest charge. Report of Foreign Bank and Financial Accounts (“FBAR”) Filings: FBAR filings on Form TD-F 90-22.1 are generally required to be made by U.S. persons who have…
Internal Revenue Service again issues annual reminder to US persons to report foreign accounts and foreign income
…as the “FBAR.” The FBAR is same as the Financial Crimes Enforcement Network Form 114. The law requires U.S. citizens, business entities and permanent residents to submit Form 114 each…
“Financial interest” or “Signature Authority” in a Foreign Account
…accounts, an FBAR is required (in FBAR Part IV) but often the due date is deferred. “Financial interest” in a Foreign Account The term “financial interest” is far less obvious…
Instructions for New Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer U.S. Taxpayers
…IRS; If FBAR penalties have been previously assessed against the taxpayer or if the taxpayer has previously received an FBAR warning letter; If the taxpayer has a financial interest or…
Opting Out of the OVDI Program: Argue for No Penalty and a Warning Letter
…results for some of our clients. Under IRM 4.26.16.4 (FBAR Penalties) (07-01-2008) whenever there is an FBAR violation, the examiner will either issue the FBAR warning letter, Letter 3800, or…
NY Art Consultant Indicted for Filing False Tax Returns and Failing to File FBARs
…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
…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…
Beware of FATCA Letters
…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…
Specific Steps for Applying to the IRS Streamlined Foreign Offshore Procedures
…5471, and 8938. In addition, the applicant must file any delinquent FBAR forms for the past six years for which the FBAR filing requirement has passed. In order to ensure…
Analysis: IRS New Disclosure Program
…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…
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…