IRS Releases New IRS 2022 FBAR Fact Sheet
...FBAR Submission Procedure (or DFSP), which our office has successfully utilized hundreds of times to cure delinquent FBARs and immunize clients from penalties. Nonethless, the new IRS 2022 FBAR Fact...
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IRS announces an update to its Voluntary Disclosure Practice Preclearance Request and Application
...for federal income tax purposes, received previously untaxed funds, or was required to be reported on an information return or report (e.g., Form 8938 or FBAR) and was not reported....
Upcoming live video webinar: “FBAR and U.S. Tax Reporting: Compliance Requirements for Foreign Assets”
I am pleased to announce that I will be speaking in an upcoming Strafford live video webinar, “FBAR and U.S. Tax Reporting: Compliance Requirements for Foreign Assets” scheduled for Wednesday,...
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...
All the Many FBAR Late Filing Procedures
...become noncompliant and delinquent. However there are a number of different delinquent FBAR late-filing procedures U.S. taxpayers can go through to become compliant. Delinquent FBAR Submission Procedures or DFSP A...
A Lesson to be Learned from US v. Schwarzbaum: Bring Back the Foreign Funds to Pay FBAR Penalties
...gifts were deposited into Swiss bank accounts which were controlled by Schwarzbaum. Thereafter, Schwarzbaum did not timely file his FBARs for said foreign accounts and a willful FBAR penalty case...
Do You Have to Pay US Taxes on Foreign Inheritance?
...These reporting requirements include, but are not limited to, the timely filling of a FinCEN Report 114 (FBAR) and IRS Form 8938 (Statement of Specified Foreign Financial Assets) which merely...
FBAR Deadline Extended to December 31, 2021
The Financial Crimes Enforcement Network (FinCEN) today issued a notice extending the filing date of Reports of Foreign Bank and Financial Account (FBARs) for victims of recent natural disasters, including...
Pandora’s Box Has Opened: Pandora Papers
...law, many U.S. taxpayers with foreign accounts exceeding certain thresholds must file Form 114, Report of Foreign Bank and Financial Accounts, known as the “FBAR.” It is filed electronically with...
An Ill-advised IRS Streamlined Filing Compliance Procedure Filing
...failure to file FBARs and tax returns was non-willful.” Apparently, his Streamlined filing was for foreign accounts valued at over $93 million. Not surprisingly the large account filing was further...
Upcoming live video webinar: U.S.-India Tax Planning: Reporting Issues, Traps to Avoid, Tax Treaties, FTC, FACTA/FBAR Reporting, Passive Income
I am pleased to announce that I will be speaking in an upcoming Strafford live video webinar, “U.S.-India Tax Planning: Reporting Issues, Traps to Avoid, Tax Treaties, FTC, FACTA/FBAR Reporting,...
Unfiled FBAR Penalties Survive Death
...determined that the FBAR civil nonwillful penalty was remedial, which survives death and becomes an estate liability. Many cases in the past have held that the FBAR willful penalty, which...