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Information Sharing of Account Holder Information Officially Begins

7 October, 2015

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 also receive information from the

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IRS Announces Key Milestone in FATCA Implementation; U.S. Begins Reciprocal Automatic Exchange of Tax Information under Intergovernmental Agreements

4 October, 2015

IR-2015-111, Oct. 2, 2015 WASHINGTON — The Internal Revenue Service today announced the exchange of financial account information with certain foreign tax administrations, meeting a key Sept. 30 milestone related to FATCA, the Foreign Account

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

3 October, 2015

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

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Caution: Foreign Businesses Require Additional Reporting

28 September, 2015

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

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New FBAR Deadline applies to 2016 Tax Year Onwards

27 September, 2015

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

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FATCA Deadlines Extended

18 September, 2015

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

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IRS delinquent FBAR submission procedure

11 September, 2015

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

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Watch Out for PFIC Status

31 August, 2015

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

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Top FBAR Reporting Error

27 August, 2015

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

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Correcting Common FBAR Errors

4 August, 2015

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

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New FBAR FIling Deadline Law Signed

31 July, 2015

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

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Below is a List of Common Forms Applicable in Compliance Requirements for U.S. Citizens and Residents with Foreign Assets, Trusts, and Entities

28 July, 2015

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

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  • About Patel Law Offices
  • Delinquent FinCen Form 114 (FBAR) Filings
  • Delinquent or unfiled IRS Form 5471

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