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DHS to Wind Down DACA Program Over a Six-Month Period

On September 5, 2017, the U.S. Department of Homeland Security (“DHS”) issued a Memorandum and Frequently Asked Questions announcing the winding down of the program known as Deferred Action for Childhood Arrivals (“DACA”). ...more

Deadline: Foreign Bank Account Reports Due June 30, 2016

Any U.S. person who has a financial interest in or signature authority over one or more foreign financial accounts with an aggregate value over $10,000 (on any day of the year) must report the accounts to the Treasury...more

U.S. Expatriates Eligible to Open State Department Federal Credit Union Accounts

Due to a combination of factors, including increased enforcement of U.S. anti-money laundering and trade sanction laws and fear of securities law violations, a number of U.S. financial institutions have closed out existing...more

Passport May Be Revoked If Owing More Than $50,000 in Taxes

On December 4, 2015, the Fixing America’s Surface Transportation Act (the FAST Act) was signed into law. Among other items, the FAST Act gives the Internal Revenue Service (IRS) and the Department of the Treasury power to...more

Updates on Offshore Financial Account Compliance and Small Business Audit Considerations

Recently, IRS officials, including Commissioner John Koskinen, have stated that the streamlined filing program for the disclosure of previously unreported foreign financial accounts would not last forever and would end at...more

FIRPTA Withholding Tax Rate to Increase 15 Percent on February 2016

On December 18, 2015, the Protecting Americans from Tax Hikes Act (the Act) was signed into law. Among other items, the Act materially amends the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) to increase the...more

Possible Changes to IRS Audits of High Income Individuals

The Internal Revenue Service (IRS) is considering increasing the income threshold to identify a taxpayer as being wealthy enough to be audited by the IRS’s High-Income and High-Wealth Strategy Team. The recommendation to do...more

12/13/2015  /  Audits , High Net-Worth , Income Taxes , IRS

Changes in Tax Return and FBAR Due Dates and Extensions

The deadline for filing tax returns and Foreign Bank Account Report (FinCEN Form 114) (FBAR) has been changed by the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015. Below is a brief summary of...more

Innocent Spouse Relief Granted Due to Spousal Abuse Even If Requesting Spouse Had Knowledge of Tax Deficiency

In a recent Tax Court case, innocent spouse relief was granted to a Florida taxpayer to relieve her from over $400,000 in tax deficiency and penalties. Tax Court typically is reluctant to grant innocent spouse relief when the...more

$10,000 in Cash Receipts? Heightened Penalties for Failure to File Form 8300 Within 15 Days

Any person who, in its trade or business, receives cash in the amount of more than $10,000 in a single transaction or a series of related transactions must file Form 8300, Report of Cash Payments Over $10,000, Received in a...more

Cross-Border Activities: Benefits of Filing “Protective” Returns

With the increasing focus by the Internal Revenue Service (IRS) on offshore activities, it is important to understand the tax return and information return filing obligations that may be associated with such activities....more

IRS New Guidance Significantly Reduces Maximum FBAR Penalties

To moderate the draconian Foreign Bank and Financial Accounts (FBAR) violation penalties under Title 31 of the U.S. Code, the IRS just published guidance that significantly reduces willful and non-willful FBAR violations....more

June 30 Deadline: Foreign Financial Account and Asset Reporting Obligations

Do you maintain bank accounts outside the U.S.? Do you own any foreign financial assets, such as foreign stock or a loan to a foreign person? If you do, you should be aware that you may have extra reporting obligations to the...more

DEADLINE: Foreign Bank Account Reports Due June 2015

Any U.S. person who has a financial interest in or signature authority over one or more foreign financial accounts with an aggregate value over $10,000 (on any day of the year) must report the accounts to the Treasury...more

5/18/2015  /  FBAR , Filing Deadlines , FinCEN , U.S. Treasury

Large Increase in Fee to Renounce Citizenship

Beginning September 6, 2014, the U.S Department of State fee to renounce U.S. citizenship increased fivefold—from $450 to $2,350. The increase, intended to discourage dual citizens from renouncing U.S. citizenship, comes...more

Deadline: Foreign Bank Account Reports Due June 30, 2014

Any U.S. person who has a financial interest in or signature authority over one or more foreign financial accounts with an aggregate value over $10,000 (on any day of the year) must report the accounts to the Treasury...more

Deadline: Foreign Bank Account Reports Due June 30, 2013

Any U.S. person who has a financial interest in or signature authority over one or more foreign financial accounts with an aggregate value over $10,000 (on any day of the year) must report the accounts to the Treasury...more

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