BE-10 Report: A New Overlooked International Reporting Form

- By : Parag Patel

The Bureau of Economic Analysis (BEA) is an agency of the U.S. Department of Commerce and is currently conducting a benchmark BE-10 survey which entails the filing of a BE-10…

National Taxpayer Advocate calls IRS Penalties Draconian and Inefficient

- By : Parag Patel

…and crossborder business activities are potentially subject to a wide range of U.S. reporting requirements. Many of these requirements come with significant penalty exposure when a filing is late, incomplete,…

Resolving IRS disputes through audit reconsideration

- By : Parag Patel

…It is also the process the IRS uses when the taxpayer contests a Substitute for Return (SFR) determination by filing an original delinquent return. [IRM §4.13.1.2(1)] Although the Internal Revenue…

Common Issues for US-India Tax Reporting

- By : Parag Patel

…for financial accountholders. The Indian government said that the account holders of any Indian financial institutions need to provide self-certification of compliance under US Foreign Account Tax Compliance Act (FATCA)….

Foreign Account Tax Compliance Act (FATCA) online registration program is launched

- By : Parag Patel

…to take before the Foreign Account Tax Compliance Act (FATCA), enacted in 2010, takes effect in July 2014 with steep penalties for firms that do not comply. FATCA requires foreign…

India and the US have agreed to collaborate on offshore tax evasion

- By : Parag Patel

…believed to have foreign contacts for a FATCA Compliance Certificate. Technically, there is no FATCA Compliance Certificate, per se. Practically speaking, a FATCA Compliance Certificate simply refers to that indicates…

India issues FATCA Self-certifications and KYC Warnings

- By : Parag Patel

…financial institutions need to provide self-certification of compliance under US Foreign Account Tax Compliance Act (FATCA) by April 30, 2017. Failure to provide self-certification of compliance would result in the…

Foreign Account Tax Compliance Act (FATCA): More Information Sharing Agreements Expected

- By : Parag Patel

FATCA was enacted in 2010 by Congress to target non-compliance by U.S. taxpayers using foreign accounts. FATCA requires foreign financial institutions (FFIs) to report to the IRS information about financial…

IRS Announces New international campaigns

- By : Parag Patel

…income tax filings and filings under 31 CFR 1010.350 requiring disclosure of foreign financial accounts on FinCEN Form 114 (commonly known as FBARs). Recently, John Cardone, director (withholding and international…

US FATCA Enforcement Softens due to Coronavirus

- By : Parag Patel

The Internal Revenue Service is giving foreign banks and financial institutions more time to file their forms about U.S. taxpayers with overseas bank accounts and other holdings in compliance with…

New IRS Form 8938 Statement of Foreign Financial Assets is causing significant confusion

- By : Parag Patel

As anticipated, IRS Form 8938 Statement of Foreign Financial Assets is causing significant confusion among taxpayers attempting to complete these Forms for filing. Form 8938, Statement of Specified Foreign Financial…

Difference between Form 8938 and FBAR Requirements

- By : Parag Patel

…U.S. Government Accountability Office issued a study concluding that there is overlap between the two forms that “increases the compliance burden and adds complexity that can create confusion” for taxpayers….

Finally: IRS Reminds Those with Foreign Assets of U.S. Tax Obligations

- By : Parag Patel

…a U.S. tax liability and a filing requirement in 2013. The filing deadline is Monday, June 17, 2013, for U.S. citizens and resident aliens living overseas, or serving in the…

The “Quiet” or “Silent” Disclosure

- By : Parag Patel

…Sometimes filing a false return is worse that filing no return at all. Some possible criminal charges include tax evasion and filing a false return. Willfully failing to file an…

U.S. Tax Court: What to Expect

- By : Parag Patel

…all the appropriate steps and considered all your evidence.   Petition A case is started in U.S. Tax Court by filing a Petition. Things to keep in mind when filing

NY Art Consultant Indicted for Filing False Tax Returns and Failing to File FBARs

- By : Parag Patel

Last week, on July 28, 2016, the United States Department of Justice announced an indictment against Lacy Doyle for obstructing the administration of tax laws and filing false foreign bank…

ABA Conference with Government Officials

- By : Parag Patel

…issues of interest. Also discussed was the effect of streamlined program to channel most taxpayers into streamlined rather than OVDP. Government official John McDougal said that the average $10,000 payment…

Watch Out for Letters From Your Foreign Bank Requesting Information On Your U.S. Residency

- By : Parag Patel

…they are required to obtain such personal information pursuant to the U.S. Foreign Account Tax Compliance Act (“FATCA”) FATCA requires that foreign banks submit information to the United States government…

IRS expands use of Subpeonas

- By : Parag Patel

…of information, and when you couple that with what we have received from the offshore compliance initiative and the streamlined filing program, we have actually been able to secure quite…

IRS Summons to a Third Party: Duties and Rights

- By : Parag Patel

procedures in issuing and serving a summons on a third party. Failure to comply with these procedures could invalidate the summons and render it unenforceable. 1. The name and address…

Beware of FATCA Letters

- By : Parag Patel

…FBAR by US taxpayers with extensive foreign assets. Both should already have been filed for previous financial years. You should also discuss the Streamlined Filing Procedure with your tax professional….

Foreign bank account reports (FBARs) and the 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI)

- By : Parag Patel

…regulations related to FBAR filing requirements for foreign financial accounts maintained in calendar year 2010 (required to be filed by June 30, 2011) and thereafter. Revised Form FBAR instructions are…

IRS’s four offshore programs have netted 39,000 taxpayers and over $5.5 billion

- By : Parag Patel

…OVDP data, the IRS identified bank names and account locations that helped it pursue additional noncompliance. Based on a review of the cases, the GAO found examples of immigrants who…

Received a FATCA Letter from Your Foreign Bank?

- By : Parag Patel

…2014, those holding accounts in foreign banks throughout the world have received Foreign Account Tax Compliance Act (FATCA) letters from their financial institutions. These letters are sent to account holders…

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

- By : Parag Patel

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…

New offshore voluntary disclosure program (OVDP) changes expected to be favorable to taxpayers

- By : Parag Patel

…accounts whose prior non-compliance clearly did not constitute willful tax evasion,” he continued, “but who, to date, have not had a clear way of coming into compliance that does not…

Argue for No Penalty and a Warning Letter for FBAR Violations

- By : Parag Patel

…would be sufficient to bring the individual into compliance, an IRS official recently said. Jason Kuratnick, IRS associate area counsel (Philadelphia), Small Business/Self-Employed Division, explained that the Office of Chief…

Taxpayers’ Evidence of Non-Willfulness or Willfulness Factors

- By : Parag Patel

…not know about including offshore income on his/her U.S. tax return or that he/she never knew about the FBAR filing requirement? What kind of supporting evidence does the taxpayer need…

Rare Supreme Court Ruling Favors Taxpayers!

- By : Parag Patel

…with foreign accounts. However, penalties are still very high for non-compliance. Noncompliant taxpayers are encouraged to use some of the voluntary disclosure programs with reasonable penalties to come into compliance….

One Month Countdown: The Deadline is Nearing for U.S. Taxpayers with Undisclosed Accounts to Come Forward

- By : Parag Patel

…and around the world with many undisclosed offshore accounts states, “The U.S. government is taking quick action to bring taxpayers into compliance by means of opening investigations into offshore banks…