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Tag: foreign account

Are You Ready For New FATCA Enforcement in 2020?

2 January, 2020

Banks and certain other financial institutions located outside the United States that have U.S. account holders are scrambling to meet a looming IRS deadline. These institutions, known as foreign financial institutions, or FFIs, must achieve

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The IRS Large Business and International division (LB&I) has announced a new Loose Filed Forms 5471 compliance enforcement campaign

1 August, 2019

The new Loose Filed Forms 5471 targeted enforcement campaign was identified through LB&I data analysis and suggestions from IRS employees. IRS employees likely received many Loose Filed Forms 5471 that were not properly filed, as

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Details of the Streamlined Foreign Offshore Procedures (SFOP)

19 July, 2019

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 a number

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The IRS Large Business and International division (LB&I) has announced a new Offshore Private Banking enforcement campaign

12 July, 2019

The new Offshore Private Banking enforcement campaign was recently identified through LB&I data analysis and suggestions from IRS employees. IRS employees likely saw that many taxpayers were not properly reporting offshore bank accounts, as a

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Details of the Streamlined Domestic Offshore Procedures

2 July, 2019

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 a number

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Details of the Delinquent International Information Return Submission Procedures (DIIRSP)

19 May, 2019

The Delinquent International Information Return Submission Procedures are one of the four methods for taxpayers with unreported offshore accounts to become compliant.  Taxpayers who have failed to file certain international-related information returns.  It applies to all

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New IRS Voluntary Disclosure in 7 Steps

10 December, 2018

The following are the seven steps of the new updated IRS voluntary disclosure process: A taxpayer will make a voluntary disclosure preclearance request using IRS Form 14457 to IRS Criminal Investigation (CI). Taxpayers can request

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Federal District Court Holds that FBAR Penalties in Excess of $100,000 is Unlawful

4 June, 2018

Recently, the U.S. District Court for the Western District of Texas in U.S. v. Colliot, determined that an individual who repeatedly failed to timely file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts, commonly

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New FBAR Court Case Makes it Easier for Taxpayers to be Deemed Willful

21 April, 2018

There is a debate as to the “burden of proof” that must be met by the Internal Revenue Service (IRS) in asserting that an FBAR violation was “willful”.  This is significant because those who willfully

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Denied access to or withdrew from the IRS Offshore Voluntary Disclosure Program (OVDP)?

26 March, 2018

This year taxpayers who either were denied access to or withdrew from the IRS Offshore Voluntary Disclosure Program (OVDP) have been receiving Letter 5935 (HERE) from the IRS notifying them that they need to come into

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New Unreported Offshore Assets case: Bad facts leads to bad results

1 February, 2018

A resident of Connecticut who was originally from Korea has been hit with a record civil penalty of $14M, a six month prison sentence, and a fine of $100,000 for failing to report Swiss bank

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IRS Passport Revocation or Denial for Unpaid Taxes

11 December, 2017

Two years ago, Congress passed Internal Revenue Code Section 7345. This law allows the Internal Revenue Service (IRS) to work with the US State Department to suspend and/or deny the passports of taxpayers with seriously delinquent

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