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 compliance with U.S. reporting requirements
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 accounts totaling around $28M, the
Taxpayers across the country rely on advice from their accountants and CPAs to meet the complicated requirements of the U.S. Tax Code. But a new case, Jarnagin v United States, in the U.S. Court of Federal Claims suggests that CPA
The reporting requirements for IRS Form 5471 are complex, including ‘category of filer’ and required schedules. However, very few taxpayers know that there are special simplified filing rules for a foreign dormant corporation. IRS Revenue Procedure 92-70, specifies specific, conditions
The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced an automatic six-month extension for taxpayers required to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR). Taxpayers now have until October 16 to submit their FBARs for
The US Dept of Justice (DOJ) Tax Division recently published it annual summary highlights of civil tax matters. The publication is linked here (Updated through December 16, 2016), and contains brief summaries DOJ Tax activity (decisions, court filings, etc.). Last year it
The Internal Revenue Service’s efforts to prod taxpayers to disclose their offshore bank accounts and pay taxes on their holdings have reached the $10 billion mark and prompted over 100,000 taxpayers to come forward, the IRS said last Friday in
The Internal Revenue Service recently once again issued its annual reminder to US persons to report foreign accounts and foreign income. The reminders issued because of the widespread confusion and misunderstanding that exists among most US persons with foreign assets.
The U.S. Justice Department is reviewing reports about the offshore financial arrangements of global politicians and public figures based on 11.5 million leaked files from Panamanian law firm Mossack Fonseca, a department spokesman said yesterday. The department is determining whether
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
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
The US Treasury has issued long-awaited regulations specifying the domestic taxpayers who have to disclose substantial foreign financial assets to the Internal Revenue Service (IRS) every year. The new rules, effective immediately, are linked to the Foreign Account Tax Compliance
At the recent American Bar Association meeting held on January 29, 2016, the acting Attorney General for the tax division disclosed that the IRS and US Department of Justice are now focusing bank investigations in Belize, the British Virgin Islands,
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
The US Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 (the Act) has changed the filing date for the Report of Foreign Bank and Financial Accounts (FBAR), electronically filed with the Financial Crimes Enforcement Center (FinCEN) on
There is an increased focus by the Internal Revenue Service (IRS) on offshore activities. There are tax return and information return filing obligations that may be associated with foreign income, assets and transactions. Many taxpayers (including non-U.S. persons who might
You may have recently received a letter from your financial institution or investment firm asking for some of your personal details. Typically the letter requests many personal, tax and residency details, such as your country of birth, the country in
We are members of the American Bar Association Section of Taxation, which recently submitted comments to the IRS on the IRS Offshore Voluntary Disclosure Program (“OVDP”), the Streamlined Domestic Offshore Program (“SDOP”), and the Streamlined Foreign Offshore Program (“SFOP”). The comments are
There is a lot of misinformation so we decided to debunk the top myths of US tax compliance. Myth #1: I don’t have to file US taxes if I live abroad. The US is one of the few countries who
In 2009, the IRS had introduced an Offshore Voluntary Disclosure Initiative/Program (OVDI/OVDP). In following years, the program was reintroduced and revised. When it comes to addressing offshore filing deficiencies, several issues exist in connection with the statute of limitations, the
On July 31, 2015, President Obama signed into law P.L. 114-41, which included a number of tax provisions, one of which changes the deadline for filing the Report of Foreign Bank and Financial Accounts (FinCEN Form 114) (the FBAR) for 2016
Many of our tax-noncompliant clients are fearful of being involuntary discovered through the impending FATCA disclosures of their foreign accounts by their foreign banks. The Internal Revenue Service has issued a notice extending the time under which certain transitional rules
Last spring, the IRS revised its program for delinquent FBAR returns. The IRS offers a new “delinquent FBAR submission procedure”. See below excerpt from the IRS website.The program is available if you properly reported on your U.S. tax returns, and
The most common FBAR reporting mistake is simply failing to file. Some U.S. persons continue to deliberately conceal assets in secret offshore bank accounts in the hope of evading U.S. tax authorities. In many other cases, however, Americans living and
The IRS offers four options to fix FBAR mistakes. Participation in the two formal disclosure programs is permitted only if the funds held in the foreign financial account(s) are from a legal source (and not the proceeds of an illegal
1. FATCA (Foreign Account Tax Compliance Act of 2009) requires disclosure of your account information. A. July 1, 2014 FATCA withholding began. B. FATCA requires a 30 percent withholding tax on any “withholdable payment” made either to an FFI (foreign
We have come across the below 3 questions numerous times with our clients. What kind of evidence is relevant to demonstrate “non-willfulness” for purposes of the SDOP and the SFOP when the definition of non-willful conduct ranges from negligent conduct
India and the US today signed an agreement to implement the Foreign Account Tax Compliance Act (FATCA) that will facilitate exchange of information between the two countries starting on October 1, 2015. FATCA was signed by Revenue Secretary Shaktikanta Das
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 of other countries. FATCA is a
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 that the $10,000 penalty may