Foreign Account Tax Compliance Act Foreign Bank Account Report

The Foreign Account Tax Compliance Act is a United States federal statute enacted in 2010 as part of the Hiring Incentives to Restore Employment Act (HIRE Act). FATCA aims to improve compliance of U.S. taxpayers... more +
The Foreign Account Tax Compliance Act is a United States federal statute enacted in 2010 as part of the Hiring Incentives to Restore Employment Act (HIRE Act). FATCA aims to improve compliance of U.S. taxpayers by capturing tax revenue related to foreign assets and off-shore accounts.  less -
News & Analysis as of

Offshore Asset Reporting: Rules, Enforcement, and Options for Compliance

In this presentation: -Overview: Reporting Regimes for Offshore Assets -Department of the Treasury: Report of Foreign Bank and Financial Accounts (FBAR) -Form 8938, Statement of Specified Foreign...more

IRS Announces Changes to Its Offshore Voluntary Disclosure and Streamlined Procedures

On June 18, 2014, the IRS announced a number of significant changes to its Offshore Voluntary Disclosure Program (OVDP) and 2012 streamlined procedure for nonresidents and the addition of a streamlined procedure for U.S....more

Traps Within the new Streamline Offshore Account Disclosure Program

The new Streamlined Filing Compliance Procedures (the Streamline Procedures) go into effect July 1, 2014. Under the terms of the procedures some taxpayers will suffer no penalty for failure to timely file FBARs, (in the case...more

IRS Broadens Offshore Amnesty Program

Over the last several years, the Internal Revenue Service (IRS) has focused its efforts on enforcement of U.S. laws with respect to offshore assets held by U.S. citizens and residents, including their tax payment and...more

IRS Changes the Streamlined Filing Compliance Procedures and Offshore Voluntary Disclosure Program (OVDP) - Determining Your Most...

The IRS announced substantial changes to both the Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer Taxpayers and the Offshore Voluntary Disclosure Program (OVDP) on June 18, 2014....more

Former Head of DOJ Tax Division Warns Taxpayers to Think Twice Before Choosing New Streamlined Procedures

Former DOJ Tax Division AAG Kathy Keneally warned on June 24, 2014, that taxpayers should think carefully before signing a certification of non-willfulness and entering the IRS’s new Streamlined Filing Compliance Procedures....more

Offshore Tax Enforcement Update: Foreign Bank Account Disclosure Deadline Is June 2014

The annual deadline for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts (commonly known as the “FBAR” form), is fast-approaching. Any U.S. taxpayer with a financial interest in, or signature or other...more

IRS Announces Sweeping Changes To Its Offshore Voluntary Disclosure Programs: New Rules Effective July 1, 2014

On Wednesday, June 18, 2014 the Internal Revenue Service announced sweeping changes to its Offshore Voluntary Disclosure Programs, effective Tuesday, July 1, 2014. Some taxpayers are treated much more leniently under expanded...more

IRS Offshore Enforcement Update

In a recent appearance before THE U.S. Conference for International Business the IRS Commissioner stated the following: “One of the most exciting aspects of our current times is to see governments working...more

International Tax Compliance Update: IRS Hints at Coming Changes for Certain OVDP Filers

Remarks on Monday by John Koskinen, the Commissioner of Internal Revenue, indicate that the IRS is close to conceding to outside pressure to more clearly distinguish between Offshore Voluntary Disclosure Program (OVDP) filers...more

IRS Commissioner Hints That OVDP Modifications Are in the Works

Since 2009, the Internal Revenue Service has offered three different amnesty programs for taxpayers with undeclared foreign bank accounts. These programs, the current version of which is entitled the Offshore Voluntary...more

The Taxman Cometh for US Holders of Foreign Bank Accounts

U.S. citizens and residents with unreported assets abroad may be feeling a steady increase of pressure these days. The July 1, 2014 effective date of the Foreign Assets Tax Compliance Act (FATCA) is looming. The number of...more

FATCA Update: As Additional Countries Agree to Share International Tax Information, Hiding Assets Abroad becomes Increasingly...

In recent years the United States has increasingly amplified the pressure on United States persons to disclose assets they hold and income they earn abroad, especially relating to offshore financial accounts. Two prominent...more

Deadlines Coming for Multinationals’ Retirement Plans and U.S. Taxpayers with Foreign Financial Interests

In 2010, the U.S. enacted a sweeping change in enforcement of its tax laws on foreign financial interests, the Foreign Account Tax Compliance Act (FATCA). The main thrust of the act is to penalize foreign financial...more

The 3 Most Significant Tax Matters for Multinationals in 2014

What is the most significant tax consideration facing multinationals in 2014? That’s the question we recently put to leading tax advisors, asking for their quick take on the matter as we launch our new 'Need to Know' series....more

Will the U.S. Dept . of Justice Find Your Offshore Account?

At a recent tax conference a senior official of the U.S. Department of Justice DoJ) is reported to have said: “We’ll be looking for you”....more

Tax Law Blog: The Impact of FATCA

The U.S. government loses an estimated $150 billion in revenue each year from offshore tax shelters. The Foreign Account Tax Compliance Act (FATCA), which became law in March 2010, is designed to prevent tax evasion by U.S....more

FBAR Non-filers Beware of Global Information Exchange Agreements

At the most recent meeting of the Finance Ministers and Central Bank Governors on July 19 & 20, 2013 they said “We are committed to automatic exchange of information as the new, global standard and we fully support the OECD...more

Voluntary Disclosure versus Prosecution

For taxpayer’s who had direct or indirect control over offshore financial accounts which aggregated $10,000 or more in calendar year 2012 a Report of Foreign Bank or Financial Account, known as an FBAR (Form TD 90-F. 22.1) is...more

IRS Issues “John Doe Summons” to Wells Fargo Seeking Identities of U.S. Taxpayers with Offshore Accounts at First Caribbean...

Introduction - On April 30, 2013, the United States Department of Justice issued a “John Doe Internal Revenue Code” summons to Wells Fargo Bank, as a provider of correspondent bank services for Canadian Imperial Bank...more

2013 Mutual Funds and Investment Management Conference

In this presentation: - General Counsel’s Address - Keynote Address - General Session — It’s a Small World After All: How Non-U.S. Regulators Affect Your Business - General Session — Closer to...more

The 50% FBAR Penalty, Are you at Risk?

June 30 is the deadline for U.S. taxpayers, (including resident aliens) to timely report foreign financial accounts for the year ending 2012. The report form (TD 90-22.1) known as an FBAR is due if a U.S. taxpayer has control...more

New Jersey Businessman With NRI Account Pleads Guilty to Using Offshore Bank Accounts to Defraud the U.S. and Pays $2.37 Million...

Sanjay Sethi, a New Jersey businessman, pleaded guilty on January 7, 2013 to using hidden offshore bank accounts to defraud the U.S. in a so-called “Klein conspiracy.”...more

FBAR-The New Marriage Penalty

For those U.S. taxpayers who are married to non-residents there is a new form of marriage penalty if the spouses filed joint returns. To be eligible to file joint returns an election must be made with the first joint return...more

2012 Year-End Estate Planning Advisory

Now that the election is over, we anticipate having some guidance soon with respect to the numerous tax and planning issues that have been mired in uncertainty for the past two years. Many tax benefits are scheduled to...more

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