Search Results for: swiss program bank
Consequences of Filing False Streamlined Filings
The IRS Streamlined Domestic Offshore Program (“SDOP”) allows eligible U.S. Taxpayers who failed to disclose foreign financial accounts to voluntarily disclose their conduct to the IRS and pay a reduced…
Top myths of US tax compliance for Foreign Accountholders
…has major penalties. However, the IRS has modified one of its amnesty programs, the Streamlined Offshore Filing Procedures, to eliminate late filing and FBAR (Foreign Bank Account Report) penalties. Under…
New Warnings in the IRS’ Streamlined Filing Compliance Procedures
The Internal Revenue Service has recently updated the certification forms required to be filed by taxpayers seeking to avail themselves of the Streamlined Filing Compliance Procedures. The streamlined program was…
Helpful Non-willful FBAR penalty case decided by court
…at some non-willful FBAR penalty litigation. The US district court has essentially dismissed a taxpayer’s challenges to his penalty for failing to file FBARs (Report of Foreign Bank and Financial…
IRS delinquent FBAR submission procedure
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…
New IRS Subpoenae and IRS Data Mining Expected
…taxpayers, bankers, and other professionals who are involved in the world of offshore bank accounts. Given the IRS’ latest data mining efforts, our law firm expects unabated aggressive enforcement of…
The Teeth of the Foreign Account Tax Compliance Act (FATCA)
The Foreign Account Tax Compliance Act (FATCA) is about disclosure and transparency, but in part is to catch Americans trying to stash money overseas. Controversially, FATCA orders every foreign bank…
Comparison of Form 8938 and FBAR Requirements
The new Form 8938 filing requirement does not replace or otherwise affect a taxpayer’s obligation to file FinCEN Form 114 (Report of Foreign Bank and Financial Accounts). Individuals must file…
Letter to Your Spouse
…safe deposit box at the bank. You have received a copy of my will and an additional copy is in ________________. Executors. I have appointed _______________________ and ___________________ to serve…
US Court finds non-willful FBAR penalty not limited to $10,000 per year
…bank account reports (FBARs) is not limited to $10,000 per year, and may be imposed on a per account basis. If a taxpayer has a reportable foreign financial account, it…
New Jersey Transfer Inheritance Tax : How the Tax Works
…Forms Some assets (real estate, stocks and bank accounts) require the written consent of the director of the New Jersey Division of Taxation before they can be transferred. This consent…
Permanent annual automatic extensions granted for FBARs to October 15
The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced last week that, to implement the new due date for FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR),…
US Supreme Court to Rule on FBAR Penalties Case
The debate over FBAR penalties for non-willful failure to disclose all of an individual’s or business’ foreign bank accounts has reached the Supreme Court. The issue is whether the maximum…
Rare Supreme Court Ruling Favors Taxpayers!
…This week, the Supreme Court scaled back the federal penalties for failing to file required reports listing foreign bank accounts in a ruling likely to help some Americans with foreign…
The FinCEN Files Leak
…and analyses forms to combat money laundering, terrorism financing, evasion of economic sanctions and other financial crimes. The FinCEN Files impacts mainly large banks, the FinCEN leak reminds us that…
New IRS FBAR Practice Unit
…IRS (and its agents) interpret these rules. To help taxpayers and tax advisors, this article provides a summary of the FBAR Practice Unit. General: The Bank Secrecy Act (“BSA”) requires…
Financial Crimes Enforcement Network (FINCEN) Issue Final Rules
The Bank Secrecy Act (“BSA”) was originally enacted in 1970 to help detect and prevent money laundering. The BSA requires reporting for a calendar year called a “Report of Foreign…
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…
Do You Have to Pay US Taxes on Foreign Inheritance?
…Reporting Foreign Bank Accounts Holding Cash – Cash held in a foreign bank account is relatively simple to report. In addition to reporting the inheritance on Form 3520, there may…
IRS Reminds (again) Taxpayers to Report Foreign Income and Assets
…aliens to report any worldwide income, including income from foreign trusts and foreign bank and securities accounts. In most cases, affected taxpayers need to fill out and attach Schedule B…
FBAR Deadline Automatic Extension
…an interest in or signatory authority over foreign bank and financial accounts holding $10,000 or more at any time during the year must independently identify and report these interests to…
FBAR Reforms Recommended
If you have a financial interest in or signature authority over a foreign financial account, including a bank account, brokerage account, mutual fund, trust, or other type of foreign financial…
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…
Republican Party Rallies Against FATCA: Success Unlikely
…platform, according to the RNC. Approved in 2010 after a tax-avoidance scandal involving a Swiss bank, FATCA requires most foreign banks and investment funds to report to the U.S. Internal…
Becoming Un-American: Record number of US citizens renounce their US citizenship
…number of renunciations is related to an enforcement campaign by U.S. officials against undeclared offshore accounts. It intensified in 2009, after Swiss banking giant UBS AG admitted that it encouraged…
India Signs FATCA Model Intergovernmental Agreement to Share Account Information with the US
…Model 1, foreign financial institutions (FFIs) in India, i.e. an insurance company, bank, or mutual fund, would be required to report all FATCA-related information to Indian governmental agencies, which would…
Delinquent or unfiled IRS Form 5471
…or 5% penalty. The streamlined program was significantly expanded by the IRS in June 2014 in order to provide a meaningful way for non-willful taxpayers to remedy past non-compliance with…
IRS Streamlines its Streamlined Offshore Procedures with More User Friendly Forms
…with filing the appropriate certification form, a taxpayer entering the streamline program must submit delinquent and/or amended tax returns for each of the most recent three tax years. Delinquent FBARs…
ABA Conference with Government Officials
…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…
American Bar Association Publishes Article Entitled “Tax Law” in the October/November 2006 issue of American Bar Association’s GPSOLO magazine
…law quickly. There are over two dozen law schools throughout the United States that offer an LL.M in tax law program. There are literally hundreds of treatises and resources available…