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Top 4 Exceptions to FBAR Filing Requirement

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Top 4 Exceptions to FBAR Filing Requirement

27 June, 2015

FBARs are due this week (again). Below are the top 4 exceptions we often see for the FBAR filing requirement. Certain Accounts Jointly Owned by Spouses – the spouse of...

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Received a FATCA Letter from Your Foreign Bank?

24 June, 2015

...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...

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BE-10 Report: A New Overlooked International Reporting Form

21 June, 2015

...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...

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Beware: IRS Reminds Taxpayers of FBAR Deadline

19 June, 2015

...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...

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New IRS Guidelines for Willful FBAR violations

6 June, 2015

...notable change is that IRS Counsel review is no longer required except in cases in which willful penalties have been determined. The IRS examiner has significant discretion however this provides...

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New Much-Needed Guidance for Non-Willful FBAR violations

31 May, 2015

...FBARs. In regard to non-willful violations when there are multiple accounts, the memorandum indicates in most cases only one $10,000 penalty should be imposed in each year, not $10,000 per...

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Beware of U.S. tax consequences to a foreign trust with a U.S. beneficiary

27 May, 2015

...3520 filing. The presence of a U.S. beneficiary in what had been a purely foreign trust presents tax challenges. In addition to the imposition of additional U.S. taxes and enhanced...

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The Tax Issues of Expatriation

26 May, 2015

...be taken into account for the tax year of the deemed sale without regard to other U.S. internal revenue laws. Losses from deemed sales must be taken into account to...

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Another Taxpayer Found Guilty of Failure to File FBARs and Report Foreign Income

16 May, 2015

...an account at Swiss bank Clariden Leu. The account was originally opened in the name Sukhmani Partners II. Later he changed the name on the account to Safekeep. The government...

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Helpful Non-willful FBAR penalty case decided by court

6 May, 2015

...belief that he didn’t have to report his account. The court determined that he knew of the requirement to report the account vis-a-vis Schedule B, Foreign Accounts and Trusts, which...

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A solution in a tough tax season: the IRS Streamlined Offshore Procedures

13 April, 2015

...of perjury. Evidence of non-willful behavior could include having a small account, especially in comparison to the taxpayer’s other assets; an account on which no U.S. tax is due; a...

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Beware: India to sign FATCA agreement with US for sharing of information

9 April, 2015

...U.S. law which seeks to facilitate flow of financial information. FATCA requires Indian banks to reveal account information of persons connected to the U.S. Non-compliant financial institutions could be frozen...

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