Search Results for: offshore bank accounts
FATCAts
…HNWs. FBAR reporting requires all Americans to annually report their non-US financial accounts, including bank and brokerage accounts, if the aggregate value of those accounts exceeds $10,000. Americans must also…
Should I close my foreign account?
…have a foreign bank account? Should you report all of the income from your foreign accounts or assets? Should you file Form 8938? Should you file a Report of Foreign…
New Much-Needed Guidance for Non-Willful FBAR violations
…Report of Foreign Bank and Financial Accounts (FBAR), and IRM 4.26.17,Report of Foreign Bank and Financial Accounts (FBAR) Procedures, no later than one year from the date of issuance. …
Make Sure You have Filed FATCA Compliance Certifications
…foreign account and income data to the US IRS. As a result, foreign banking secrecy no longer exists: virtually all foreign banks report bank data to the IRS. Indian investors…
Finally: IRS Reminds Those with Foreign Assets of U.S. Tax Obligations
…Schedule B asks about the existence of foreign accounts, such as bank and securities accounts, and usually requires U.S. citizens to report the country in which each account is located….
Global Enforcement of FATCA: Something to Worry About
…the info from the foreign governments. Taxpayers with undisclosed foreign accounts should be a concerned about FATCA’s far reaching implications. As a result, Taxpayers with undisclosed foreign accounts should consult…
Foreign Account Tax Compliance Act (FATCA): More Information Sharing Agreements Expected
…the US. After heavy lobbying from foreign governments and banks, the US struck a deal with governments of the UK, France, Germany, Italy and Spain in February that allowed banks…
Finally. Government Accountability Office makes recommendations to the IRS for tax laws education to immigrants
…accounts in their home country prior to immigrating to the United States. IRS officials from the Offshore Compliance Initiative office stated that although there are several FBAR education programs, none…
Appeals of penalties imposed during the Offshore Voluntary Opt-Out
…tax, and international tax problems. Our firm assists (and defends) clients and their advisors to legally disclose (and legitimize) foreign accounts. Contact us for a free consultation regarding your case….
Offshore Voluntary Disclosure Initiative/Program (OVDI/OVDP) opt-out results and updates
…dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and their advisors to legally disclose (and legitimize) foreign accounts. For…
The “Quiet” or “Silent” Disclosure
…quiet” or “silent” disclosure is that the taxpayer will just file her delinquent FBARs and amended (or original) U.S. tax returns reflecting the income associated with the offshore accounts, and…
Analysis: IRS New Disclosure Program
On November 29, 2018, the IRS released a memorandum that addressed the process for all voluntary disclosures following the end of the Offshore Voluntary Disclosure Program (“OVDP”) on September 28,…
How to Defend Against FBAR Penalties
…taxpayers who are not in compliance—from the offshore voluntary compliance submissions submitted (which often leads to other taxpayers and advisors thereto) and from banks such as UBS and HSBC who…
Interesting 2023 Foreign Account Cases
…resident taxpayers. In United States v. Burga, 132 AFTR2d 2023-6551, a California Federal District Court concluded that a widow had become aware of most foreign bank accounts established by her…
Frequently Asked Probate Questions
…distributed properly. 5) How does the surviving spouse access joint bank accounts or certificates of deposit?Certain bank accounts or certificates of deposits may be owned with right of survivorship, which…
New IRS Guidelines for Willful FBAR violations
…4.26.16, Report of Foreign Bank and Financial Accounts (FBAR), and IRM 4.26.17,Report of Foreign Bank and Financial Accounts (FBAR) Procedures, no later than one year from the date of issuance….
Estate Planning When a Spouse is Confronting Health Issues (Estate Planning for the Healthy Spouse)
…attorney can assist the community spouse in planning his or her estate when the spouse is confronting health issues. A. Asset Titling — Deeds, Bank Accounts, And Life Insurance Transfer…
Beware: IRS Form 8938 Statement of Specified Foreign Financial Assets
…from Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts, commonly referred to as the FBAR. Individuals may be required to file both reports, depending on the specific…
OVDI: Requesting issuance of a FBAR warning letter instead of penalties
…Bank and Financial Accounts,” if it would be sufficient to bring the individual into compliance, an IRS official said May 17. See Matthew Dalton, IRS May Issue Warning Letters on…
Cost of Compliance Rises under OVDP
…where accounts trigger a 50% (rather than 27.5%) penalty (on all accounts, not just accounts at the listed banks) in the IRS’s Offshore Voluntary Disclosure Program (OVDP). According to the…
Estate Planning in the Electronic Age
…wishes. If you pass away unexpectedly, your family may be precluded altogether from accessing important electronic records such as emails and bank accounts. Accordingly, you need to establish a way…
The Strange Case of U.S. v. Hughes: Willful and Non-Willful (at the Same Time?)
…Limited which was solely owned by Hughes. Ms. Hughes had a financial interest in, and signature authority over the two entities’ bank accounts for the following years. Hughes had to…
Recent Court Decision Shows Risks of IRS Streamlined Filing Compliance Procedures
…of funds in the foreign accounts, the taxpayer’s relationship with the foreign country where the foreign financial accounts are located, and the name and contact details for any professional adviser…
Are You Ready For New FATCA Enforcement in 2020?
…may now see those accounts closed or frozen. FATCA FATCA is a U.S. federal law that aims to prevent U.S. corporations and individuals from hiding assets in foreign U.S. accounts…
Some FBAR Deadlines Extended
Last week the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) again extended the deadline for certain financial professionals to file foreign bank accounting reporting forms known as FBARs. In FinCEN…
“Financial interest” or “Signature Authority” in a Foreign Account
…and clear. Under FBAR reporting regulations (31 CFR §1010.350 Reports of foreign financial accounts), accounts held in the name of entity, can create a financial interest in a person if…
For Tax Professionals: A Guide to the IRS’s Voluntary Disclosure Practice
IRS Commissioner Shulman has invited persons with unreported foreign accounts to come forward and avail themselves of the IRS’s Voluntary Disclosure Practice. That practice is described in the Internal Revenue…
US Reporting of Foreign Retirement Accounts
Many clients contact our office regarding the failure to report their foreign retirement account. Such accounts need to be fully reported on an FinCen 114 (FBAR) and IRS Form 8938….
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…
File a Protective Claim for Refund for Possible OVDP Opt Out Cases
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…