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Tag: offshore accounts

Opting-out of the Offshore Voluntary Disclosure Initiative: FBAR Penalty Mitigation Guidelines

19 May, 2012

Depending on the circumstances, we sometimes recommend some taxpayers to opt out of the voluntary disclosure initiative and allow us to demonstrate the absence of willfulness and avoid the normal FBAR penalty regime. We have

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The legal standard of “willfulness”: Opt out to avoid high penalties

1 May, 2012

Under IRS Form 1040, at the bottom of Schedule B, Part III, on Page 2, Question 7(a) states: “at any time during the previous year, did you have any interest in or signatory or other

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Should I close my foreign account?

23 April, 2012

Suppose you have a foreign bank account holding more than $10,000. You may have inherited it, used it to hide money during a dispute with your spouse or business partner, or just done it on

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Global Enforcement of FATCA: Something to Worry About

14 April, 2012

The Foreign Account Tax Compliance Act (FATCA) is about disclosure and transparency, but in part is to catch Americans trying to stash money overseas. Controversially, FATCA orders every foreign bank to track down its U.S.

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IRS attempts to demystify its new Form 8938

8 April, 2012

The IRS has finally attempted to demystify its new Form 8938. Below are some Form 8938 FAQs: Basic Questions and Answers on Form 8938       1. What are the specified foreign financial assets

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More Tax Complexity: New Form 8938

7 April, 2012

In recent years, the IRS and US Treasury have stepped up their efforts toward tracking down delinquent tax payers and enforcing payment of overdue taxes. One of these initiatives has been labeled the “Foreign Account

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Form 8938, FATCA, FBAR and penalties for all (including bankers)

5 April, 2012

The IRS and US Treasury have stepped up their efforts toward tracking down delinquent tax payers and enforcing payment of overdue taxes. One of these initiatives is the “Foreign Account Tax Compliance Act”. FATCA is

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Frequent Scenarios in Offshore Voluntary Disclosures

3 April, 2012

I have frequently seen the following scenarios in working with clients to determine whether a offshore voluntary disclosure program filing (OVDP) is appropriate and how they should report foreign account. First, a parent or grandparent

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Eleven foreign financial institutions to share their US customer account information

25 March, 2012

US authorities have offered eleven financial institutions a settlement agreement in which the US government’s investigations in those financial institutions — for aiding tax evasion — and potential prosecution would be dropped. The eleven financial

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The Teeth of the Foreign Account Tax Compliance Act (FATCA)

23 March, 2012

The Foreign Account Tax Compliance Act (FATCA) is about disclosure and transparency, but in part is to catch Americans trying to stash money overseas. Controversially, FATCA orders every foreign bank to track down its U.S.

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American Citizens Abroad (ACA) writes letter to IRS Commissioner regarding unfair offshore asset treatment

19 March, 2012

American Citizens Abroad (ACA) has written to IRS Commissioner Doug Shulman of the IRS to express the organization’s profound concern that he has not answered the Directive issued by National Taxpayer Advocate Nina Olson. In

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No tax = No Passport?

14 March, 2012

The United States Senate has passed a provision in proposed legislation that would allow the State Department to deny, limit or revoke passports to citizens with “seriously” delinquent taxes. The passport provision is part of

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