In 2009, the IRS had introduced an Offshore Voluntary Disclosure Initiative/Program (OVDI/OVDP). In following years, the program was reintroduced and revised. When it comes to addressing offshore filing deficiencies, several issues exist in connection with
If you are an American entrepreneur with a foreign business interest or operating abroad then you should be aware of U.S. tax reporting obligations on non-U.S. businesses. If a U.S. taxable person (U.S. citizens or
On July 31, 2015, President Obama signed into law P.L. 114-41, which included a number of tax provisions, one of which changes the deadline for filing the Report of Foreign Bank and Financial Accounts (FinCEN Form
Many of our tax-noncompliant clients are fearful of being involuntary discovered through the impending FATCA disclosures of their foreign accounts by their foreign banks. The Internal Revenue Service has issued a notice extending the time
Last spring, the IRS revised its program for delinquent FBAR returns. The IRS offers a new “delinquent FBAR submission procedure”. See below excerpt from the IRS website.The program is available if you properly reported on
If you invest internationally a Passive Foreign Investment Company (PFIC) could be a nightmare that could become a reality if you happen to invest in what the IRS deems a PFIC, which are taxed at
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. tax authorities. In many other
The IRS offers four options to fix FBAR mistakes. Participation in the two formal disclosure programs is permitted only if the funds held in the foreign financial account(s) are from a legal source (and not
The president signed into law today legislation that modifies the due dates for several common tax returns. These new due dates are generally ones that tax professionals have been advocating for several years to create
Foreign Financial Assets FinCEN Form 105 Report of International Transportation of Currency or Monetary Instruments FinCEN Form 114 Report of Foreign Bank and Financial Accounts (FBAR) Form 8938 Statement of Specified Foreign Financial Assets Foreign
1. FATCA (Foreign Account Tax Compliance Act of 2009) requires disclosure of your account information. A. July 1, 2014 FATCA withholding began. B. FATCA requires a 30 percent withholding tax on any “withholdable payment” made
We have come across the below 3 questions numerous times with our clients. What kind of evidence is relevant to demonstrate “non-willfulness” for purposes of the SDOP and the SFOP when the definition of non-willful
