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
How Will the IRS Find Out By Your Foreign Account? Let’s Count the Dozens of Ways
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
Taxpayers’ Evidence of Non-Willfulness or Willfulness Factors
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
India and US signed FATCA Agreement Today
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
India Expected to Sign FATCA Agreement Tomorrow
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
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
Vatican Signs FATCA Agreement
Praying may not be enough for non-compliant taxpayers (or evaders) under the Foreign Account Tax Compliance Act (FATCA). The Vatican has become the latest FATCA signatory to share bank information with the US. The Vatican
Educational Panel Discussion: The U.S. Government’s Global Crackdown on Tax Evasion: Where It Has Been and Where It Is Going
Last we spoke at a SABANA tax section bar association educational panel “The U.S. Government’s Global Crackdown on Tax Evasion: Where It Has Been and Where It Is Going” for attorneys in Orlando FL. Fellow
Beware: IRS Reminds Taxpayers of FBAR Deadline
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
New IRS Guidelines for Willful FBAR violations
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),
The Tax Issues of Expatriation
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
IRS expands use of Subpeonas
The U.S. Internal Revenue Service is planning to broaden the use of subpoenas of documents in cases where the name of a taxpayer under investigation is not known. The so-called John Doe summonses were a