...permanent U.S. resident, kept between approximately $4,000,000 and $7,500,000 in assets in two bank accounts with UBS from at least 2002 through 2007. March 18, 2014 — California attorney Christopher...
...previously been contacted regarding an income tax examination or a request for delinquent returns for the years for which the delinquent FBARs are submitted. You must include “a statement explaining...
...PFIC’s return over your entire holding period and applying an interest charge. Most capital gains are taxed at a top federal rate of 20%, plus the Obamacare surcharge of 3.8%,...
...by Americans through financial entities of other countries. FATCA is a U.S. law which seeks to facilitate flow of financial information. FATCA requires Indian banks to reveal account information of...
...must file a BE-10 report on its own behalf and a BE-10 report on the behalf of each U.S. business enterprise that is part of the ownership chain of the...
...B asks about the existence of foreign accounts, such as bank and securities accounts, and generally requires U.S. citizens to report the country in which each account is located. In...
...the facts and circumstances of each case,” and that it will depend on tax professionals “to help taxpayers get the right answer in individual cases.” Evidence of willfulness often includes...
...and circumstances of each case,” and that it will depend on tax professionals “to help taxpayers get the right answer in individual cases.” Evidence of willfulness often includes the following:...
...one or the other: either enter the 2014 OVDP or enter the 2014 Streamlined Programs. If rejected from the 2014 Streamlined Programs, taxpayers may not later enter the 2014 OVDP...
...of the law. For information on the meaning of foreign financial asset, see the instructions for FinCEN Form 114, which may be found at FinCen and the instructions for Form...
...annuallyto the Internal Revenue Service by filing electronically a Financial Crimes Enforcement Network (FinCEN) Form 114, Report of Foreign Bank and Financial Accounts (FBAR). On September 20, 2013, FinCEN posted...
...wealthy Americans. Last month Credit Suisse, which was one of 14 category one banks, became the largest bank in decades to plead guilty to a U.S. criminal charge and will...
