Tag Archives: penalties and interest

Complicated Form 5471 filing requirements simplified for dormant foreign corporations

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

US Entities with foreign assets have more information reporting

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

The Tax Heat is On

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,

What FATCA Means to You and Your Investments

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

Top myths of US tax compliance for Foreign Accountholders

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

File a Protective Claim for Refund for Possible OVDP Opt Out Cases

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

Correcting Common FBAR Errors

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

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

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