...issues exist in connection with the statute of limitations, the nature of the error/omission, and the taxpayer’s intent. Many clients have been receiving conflicting advice and as result are often...
...signing authority over a business-related financial account, a Foreign Bank Account Report (FBAR) must be filed annually to disclose the account to the U.S. Treasury Department. Failure to properly make...
...financial institutions (limited FFIs); and (3) the deadline for a sponsoring entity to register its sponsored entities and redocument such entities with withholding agents. Separately, IRS Notice 2014-33 states that...
...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...
...clients to the IRS, PFIC rules will be enforced. Fortunately, there are a few solutions out of PFIC status: First, if the PFIC meets certain accounting and reporting requirements (which...
...of the highest account balance for each year that remained open under the statute of limitations.[10] Many who deliberately concealed offshore bank accounts have been prosecuted and received prison terms....
...accounts during the eight-year period. The penalty is increased to 50 percent if the IRS or DOJ has initiated an investigation of the financial institution in which the accounts are...
...required to: a. Obtain information from each account holder as is necessary to determine which accounts are “U.S. accounts” b. Comply with verification and due diligence procedures with respect to...
...of foreign entities to hold title to the account. Was an entity used when the account was opened? If so, did the bank require the use of an entity? Was...
...information about US account holders directly to the Indian government which will, in turn, relay that information to the IRS. Which Banks are Reporting? Many Indian financial institutions have already...
...to the IRS, third-party information reporting about financial accounts, including the identity and certain financial information associated with the account, which they maintain offshore on behalf of U.S. individual account...
...be the first intergovernmental agreement between the United States and the Holy See (Vatican), and has been characterized by the Vatican as a significant step in combined efforts to thwart...
