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
Information Sharing of Account Holder Information Officially Begins
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
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
FATCA Deadlines Extended
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
New FBAR FIling Deadline Law Signed
The president signed into law today legislation that modifies the due dates for several common tax returns. These new due dates are generally ones that tax professionals have been advocating for several years to create
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
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
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
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),
New Much-Needed Guidance for Non-Willful FBAR violations
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
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