Tag Archives: FBAR
New Much-Needed Guidance for Non-Willful FBAR violations
Last week, the Internal Revenue Service released interim guidance (SBSE-04-0515-0025) on foreign bank account report (FBAR) (also known as FinCen 114) penalties to improve the administration of the FBAR compliance program. The guidance contains amendments to the Internal Revenue Manual (IRM),
Beware of U.S. tax consequences to a foreign trust with a U.S. beneficiary
There are many U.S. tax consequences to a foreign trust and a beneficiary of a foreign trust who is or becomes a U.S. citizen or resident alien. In this article it is assumed that the grantor is and always will be
The Tax Issues of Expatriation
The “United States Permanent Resident Card”, also known as a Green Card, as a work and residence permit for the USA of unlimited duration and as an immigration visa, constitutes an admission ticket to the USA. However, possession of a
IRS expands use of Subpeonas
The U.S. Internal Revenue Service is planning to broaden the use of subpoenas of documents in cases where the name of a taxpayer under investigation is not known. The so-called John Doe summonses were a breakthrough for the IRS in
Another Taxpayer Found Guilty of Failure to File FBARs and Report Foreign Income
Raju Mukhi of St. Louis MO was indicted last year for his alleged failure to file a report to the IRS on his foreign financial accounts and for filing false tax returns. United States citizens are required to report income
Helpful Non-willful FBAR penalty case decided by court
For the first time, in the case of James Moore, Plaintiff v. United States of America, Defendant (James Moore v. U.S. Case 2:13-cv-02063-RAJ filed 4/1/15), we finally get a look at some non-willful FBAR penalty litigation. The US district court
A solution in a tough tax season: the IRS Streamlined Offshore Procedures
In the midst of tough tax season, many U.S taxpayers are unfortunately surprised to discover that they have a U.S. tax reporting obligation on financial accounts or assets held overseas. Once they discover their tax and reporting obligation, there are
Beware: India to sign FATCA agreement with US for sharing of information
Earlier this week, the Indian Cabinet, chaired by Prime Minister Narendra Modi, approved signing of an Inter-Governmental Agreement (IGA) between India and the U.S. for implementation of the U.S. Foreign Account Tax Compliance Act (FATCA). Indian Finance Minister Arun Jaitley this
FATCA Repeal Fails
Last month US Senator Roger Wicker (R-Miss.) introduced a budget amendment SA 621 to repeal the Foreign Account Tax Compliance Act (FATCA) FATCA requires foreign financial institutions to disclose to the IRS about their U.S. customers’ accounts. The U.S. loses
Another Swiss Bank Discloses Customer Names to the US
The Department of Justice announced today that BSI SA, one of the 10 largest private banks in Switzerland, is the first bank to reach a resolution under the Department of Justice’s Swiss Bank Program. Swiss private bank BSI SA avoided prosecution
Seminar: Navigating Foreign Waters: The Complex Requirements of Foreign Accounts Compliance on US tax laws
With the IRS aggressively targeting taxpayers with unreported offshore accounts, tax professionals must know benefits and pitfalls of offshore accounts. Our firm presented technical seminars titled Navigating Foreign Waters: The Complex Requirements of Foreign Accounts Compliance on US tax laws to tax professionals on foreign account disclosure,
Hiding Money or Income Offshore Among the “Dirty Dozen” List of Tax Scams for the 2015 Filing Season
IR-2015-09, Jan. 28, 2015 WASHINGTON — The Internal Revenue Service today said avoiding taxes by hiding money or assets in unreported offshore accounts remains on its annual list of tax scams known as the “Dirty Dozen” for the 2015 filing
Another Customer with Unreported Offshore Bank Accounts Pleads Guilty
George Landegger, CEO of pulp and paper company, pleaded guilty last week in New York to a federal charge of failing to file a required report to the IRS about the account. He admitted that he maintained the undeclared account
Internal Revenue Service announces new International Data Exchange Service: The Beginning of Information Sharing
The Internal Revenue Service announced this week the opening of the International Data Exchange Service (IDES) for enrollment. Financial institutions and host country tax authorities will use IDES to securely send their information reports on financial accounts held by U.S.
News from the 2014 Criminal Fraud and Tax Controversy Conference
We just returned last week from attending the Criminal Fraud and Tax Controversy Conference in Las Vegas, sponsored by the American Bar Association Section of Taxation where many government officials were in attendance. Below are some interesting observations: On the
IRS Releases Training Documents on Offshore Voluntary Disclosure Program
last month the IRS released more than 6,500 pages from the Internal Revenue Service on the agency’s Offshore Voluntary Disclosure Program and how it trains its agents. The documents included material used in training IRS personnel in the Offshore Voluntary Disclosure Program,
IRS Streamlined Filing Compliance Procedures Seminar
The Internal Revenue Service announced major changes in its offshore voluntary compliance programs, providing new streamlined filing compliance procedures to help both taxpayers residing overseas and those residing in the United States. The streamlined filing compliance procedures are game changers
OVDP New Forms Announced by IRS
The IRS has simplified the process of entering the OVDP Program by issuing the following forms: Form 14457 – Offshore Voluntary Disclosure Letter Form 14454 – Offshore Voluntary Disclosure Program Letter Attachment The new forms (the old forms were simple Word documents)
Major changes to IRS offshore voluntary compliance programs
Many clients are asking our office about the new compliance solutions to clean up past errors in disclosing foreign assets. In June 2014, the IRS announced major changes to its offshore voluntary compliance programs, providing new options to help taxpayers
First Indictment for FATCA Violation Announced
Federal prosecutors charged six men Tuesday with running a complicated offshore scheme that allegedly enabled clients to manipulate stocks, avoid U.S. taxes and launder hundreds of millions of dollars. An indictment unsealed in federal court in Brooklyn alleged the men
Watch Out for Letters From Your Foreign Bank Requesting Information On Your U.S. Residency
Numerous foreign banks are sending letters to their customers demanding personal information to ascertain whether the customer is a U.S. citizen or a U.S. resident. The foreign banks typically state they are required to obtain such personal information pursuant to the U.S. Foreign Account
Citizenship renunciation fee increases as American expatriates flee FATCA
US government fees charged to Americans for renouncing their citizenship will rocket from $450 to $2,350 on September 12, 2014. The fivefold increase is probably related to the recent dramatic rise in renunciations triggered by the US Foreign Account Tax Compliance
New IRS internal procedure guidance for Streamline Filing Compliance Procedures
The IRS has published new IRS internal procedure guidance with IRM changes dated 8/13/14. The guidance is numbered WI-21-0814-1244 and titled “Streamline Filing Compliance Procedures for Accounts Management International IMF”. The guidance is here. The general legal rule is that IRM
Streamlined Procedures for U.S. Taxpayers Residing In the United States
Many of our clients are interested in the new Streamlined Filing Compliance Procedures, which were recently announced by the IRS. Therefore, we are providing more general information on the Procedures. General Eligibility: The modified Streamlined Filing Compliance Procedures are designed for only
How to Demonstrate Non-Willfulness Under The Streamlined Filing Compliance Procedures
The IRS recently announced Streamlined Filing Compliance Procedures in an effort to encourage U.S. taxpayers to come into compliance with their reporting and filing requirements associated with varying interests in foreign financial accounts and assets. The streamlined procedures require the
50% Penalty for Taxpayers Who Hold Accounts at a Bank Under Investigation
The Internal Revenue Service announced last week changes to its programs for taxpayers with undeclared offshore accounts, the latest step in a five-year campaign against such accounts held by U.S. taxpayers. The modifications greatly eased penalties for people who were unaware
IRS Announces Major New changes to the Offshore Voluntary Disclosure Program
The IRS today made significant changes to its offshore voluntary compliance programs, with the intent of providing new options to help both taxpayers residing overseas and those residing in the United States. The agency says the changes are anticipated to provide
New Streamlined Domestic Offshore Procedures (SDOP) is a Game Changer
The IRS has announced a Streamlined Domestic Offshore Procedures (SDOP), which will significantly alter all future voluntary disclosures. The SDOP is a game changer for residents and non-resident (who would use the Streamlined Foreign Offshore Procedures (SFOP)) taxpayers alike. The
FBAR Reporting Season is here
All taxpayers are reminded about FBAR reporting this year, as the process has changed. 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
New offshore voluntary disclosure program (OVDP) changes expected to be favorable to taxpayers
During Internal Revenue Service (IRS) Commissioner John Koskinen’s remarks at a speech before the United States Council-OECD International Tax Conference in Washington last week, he indicated that the agency is preparing a new offshore voluntary disclosure program (OVDP) that will
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