Search Results for: fatca letter
New Post-OVDP IRS Voluntary Disclosure Procedures Announced
…must request “preliminary acceptance” (which is analogous to the old OVDP program) by submitting all required voluntary disclosure documents using a new revised Form 14457 (voluntary disclosure letter). This form…
2011 Offshore Voluntary Disclosure Initiative (OVDI)
…letter, consent to extend FBAR statute, consent to extend statute to assess tax, penalty computation spreadsheet, sample Form 2848 – Power of Attorney and Declaration of Representative Submission Requirements from…
Start or review an “Accountable Plan”
…clubs; Golf and athletic clubs; Sporting events; and Hunting and fishing. Reimbursement for small tools can be a gray area that should be documented carefully (see Rev. Rul. 2012-25 and IRS Letter…
IRS Most Common Tax Notices and What They Mean
…notice should contain the tax year and a “notice” or “letter number” on the top right-hand side of the first page. Some of the most common IRS tax notices…
Fantastic Recommendations for Form 3520
…3520 and Form 3520-A penalty notices, the practitioner community has observed that Campus personnel routinely deny penalty abatement and then issue a Letter 854C. The only recourse for taxpayers after…
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…
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….
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…
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…
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…
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….
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…
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,…
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…
2020 New Year’s Tax Planning Resolutions: Resolve To Plan Better
…foreign accounts. The IRS has publicly stated that foreign accounts tax compliance is a priority in enforcement. In 2019, the IRS announced that it began mailing warning letters to certain…
New IRS Disclosure Program Announced for Non-Resident Taxpayers: Streamlined Foreign Offshore Procedures
The United States’ IRS is moving to entice more taxpayers to disclose their unreported assets and income just weeks before implementation of the U.S. Foreign Account Tax Compliance Act (FATCA)….
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…
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…
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…
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…
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…
IRS collects over $5 billion in its its offshore voluntary disclosure programs
…specific financial institution. Our law firm expects unabated aggressive enforcement of the US tax laws, including FATCA with increased criminal prosecutions and civil audit examinations. We have been advising our…
OVDP Ineligibility Possibility Increases
…there is no stated deadline) because of the IRS’ continuing investigation of foreign banks. Our law firm expects unabated aggressive enforcement of the US tax laws, including FATCA with increased…
IRS Announces Penalty Mitigation for Smaller US Taxpayers Living Abroad
…the US tax laws, including FATCA with increased criminal prosecutions and civil audit examinations. We have been advising our clients to expect the unexpected (and the worst) in their tax…
FBAR Deadline Automatic Extension
…account disclosures that must now be made on a taxpayer’s annual income U.S. income tax return (e.g. Form 1040, Schedule B; and Form 8938 –“FATCA” disclosure). Beginning for the 2016…
Analysis of the new 2012 Offshore Voluntary Disclosure Program (OVDP)
…Account Tax Compliance Act (FATCA) and Foreign Financial Asset Reporting (Form 8938 and new IRC § 6038D) become effective. It is likely that the U.S. government will require foreign financial…