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Tag: offshore

India Expected to Sign FATCA Agreement Tomorrow

8 July, 2015

India is expected to sign an inter-governmental agreement (IGA) for the US tax compliance law Foreign Account Tax Compliance Act (FATCA) tomorrow. FATCA is aimed at combating possible tax evasion by Americans through financial entities

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Penalties for Form 5472 Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business

28 June, 2015

We would like to highlight a recent change in the IRS’ policy with respect assessing statutory late filing penalties related to certain international information forms. Of particular concern to international businesses is the revised policy

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Received a FATCA Letter from Your Foreign Bank?

24 June, 2015

If you have any US connections and have a non-U.S. bank account, you may have recently received a letter from your bank asking for your tax information. This may seem odd or new to you

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Beware: IRS Reminds Taxpayers of FBAR Deadline

19 June, 2015

Last week, the Internal Revenue Service reminded all taxpayers with a filing requirement for a foreign bank account report to report their foreign assets by the June 30 deadline.  The IRS has been targeting FBAR

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New IRS Guidelines for Willful FBAR violations

6 June, 2015

Last week, the Internal Revenue Service released interim guidance (SBSE-04-0515-0025) on foreign bank account report (FBAR) penalties to improve the administration of the FBAR compliance program. The guidance contains amendments to the Internal Revenue Manual (IRM),

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New Much-Needed Guidance for Non-Willful FBAR violations

31 May, 2015

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

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

27 May, 2015

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

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The Tax Issues of Expatriation

26 May, 2015

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

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FATCA Repeal Fails

3 April, 2015

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.

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Another Swiss Bank Discloses Customer Names to the US

31 March, 2015

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

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Seminar: Navigating Foreign Waters: The Complex Requirements of Foreign Accounts Compliance on US tax laws

2 March, 2015

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

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New Warnings in the IRS’ Streamlined Filing Compliance Procedures

31 January, 2015

The Internal Revenue Service has recently updated the certification forms required to be filed by taxpayers seeking to avail themselves of the Streamlined Filing Compliance Procedures.  The streamlined program was significantly expanded by the IRS

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Recent Posts

  • Parag Patel Esq. speaker at the National Association of Enrolled Agents (NAEA) Seminar “2025 Mid-Year Update”September 1, 2025
  • The Complex Landscape of FBAR and Foreign Asset Reporting: A Critical Webinar Update for Tax Professionals (Free)August 31, 2025
  • The Department of Justice’s Focus on Employment Tax CrimesAugust 29, 2025
  • Dr. Sriram Case: A Summary of Key Tax and Legal IssuesAugust 28, 2025
  • All Things Appeals Webinar: A Strategic Guide for Tax ProfessionalsAugust 26, 2025

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  • About Patel Law Offices
  • Delinquent FinCen Form 114 (FBAR) Filings
  • Delinquent or unfiled IRS Form 5471
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