The IRS has begun receiving information regarding tax year 2014 from nations around the world who have agreed to comply with FATCA. Some of those countries negotiated reciprocal agreements to also receive information from the
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
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
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
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
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
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
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
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
For the first time, in the case of James Moore, Plaintiff v. United States of America, Defendant (James Moore v. U.S. Case 2:13-cv-02063-RAJ filed 4/1/15), we finally get a look at some non-willful FBAR penalty
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
Earlier this week, the Indian Cabinet, chaired by Prime Minister Narendra Modi, approved signing of an Inter-Governmental Agreement (IGA) between India and the U.S. for implementation of the U.S. Foreign Account Tax Compliance Act (FATCA). Indian
