FATCA, Foreign Financial Accounts

FBARs, FATCA, and Foreign Nationals: Where are We Headed?

Buchalter on 8/30/2023

There has been a legal shakeup this summer in the world of “FBARs”—Reports of Foreign Bank and Financial Accounts. New developments have been popping up nearly every week, whether from a court decision, as a result of a...more

Often Overlooked Exception to Withholding and Reporting Requirements under FATCA

Dorsey & Whitney LLP on 2/3/2021

An often overlooked exception to U.S. withholding taxes may result in a lower overall U.S. tax burden. The Foreign Account Tax Compliance Act (“FATCA”) was enacted in an effort to ensure that U.S. taxpayers could not...more

IRS Continues to Cross-Reference Foreign Financial Accounts and Assets

Foodman CPAs & Advisors on 4/1/2019

IRS holds information that is sourced from the FATCA reports submitted by Foreign Financial Institutions (FFI) (on Form 8966 - FATCA Report) and by Individual US Taxpayers that have reporting obligations via Form 8938...more

Offshore Accounts Today Equal Transparency

Foodman CPAs & Advisors on 12/17/2018

The days of avoiding taxes through hiding money or assets in unreported offshore accounts are gone. Nonetheless, there are still taxpayers with undeclared offshore accounts, as well as the banks and bankers that are...more

Despite Closure Of OVDP, Offshore Tax Evasion Crackdown Marches On

Fox Rothschild LLP on 11/1/2018

On September 29, 2018, the Internal Revenue Service closed for good the long-running Offshore Voluntary Disclosure Program (OVDP), its hugely successful tax amnesty program for undisclosed offshore financial assets. Since...more

DOJ Secures First Ever Conviction for Violating FATCA

Ballard Spahr LLP on 9/18/2018

The Department of Justice (“DOJ”) has secured its first conviction ever under the Foreign Account Tax Compliance Act, or FATCA, through the guilty plea of Adrian Baron, a former executive of Loyal Bank Ltd., a bank with...more

IRS ENDS OVDP right when some Taxpayers GET IT!

Foodman CPAs & Advisors on 9/17/2018

On March 13, 2018, IRS announced the termination of the Offshore Voluntary Disclosure Program (OVDP) as of September 28, 2018 (Notice IR-2018-52). ...more

¡FATCA Se Está Enforzando A Pesar De Hipos Y Reporte De TIGTA!

Foodman CPAs & Advisors on 8/27/2018

El 5 de Julio del 2018, el Inspector General del Tesoro para la Administración Tributaria (TIGTA) emitió un informe: https://www.treasury.gov/tigta/auditreports/2018reports/201830040fr.pdf titulado: "A pesar de gastar casi...more

FATCA Is Being Enforced Despite Hicups And TIGTA Report!

Foodman CPAs & Advisors on 8/27/2018

On July 5, 2018, the Treasury Inspector General for Tax Administration (TIGTA) issued a report https://www.treasury.gov/tigta/auditreports/2018reports/201830040fr.pdf titled: “Despite Spending Nearly $380 Million, the...more

The Perils Facing a U.S. Person Having an Undeclared Offshore Financial Account

Baker Donelson on 8/10/2018

There are legal and financial consequences to any U.S. person who underreports their income. Moreover, similar consequences may exist even in a situation in which all income is reported, yet certain information returns are...more

FATCA is still Standing!

Foodman CPAs & Advisors on 5/17/2018

Tax Reform came and went and FATCA is still standing. While U.S. Corporations are now moving to a Territorial tax system, Individual U.S. Taxpayers living abroad ARE STILL REQUIRED to REPORT their worldwide income. ...more

At any time during 2017, did you have a financial interest in or signature authority over a financial account (such as a bank...

Foodman CPAs & Advisors on 4/13/2018

On April 9, 2018, IRS released Notice (IR-2018-87) to remind Taxpayers that hold foreign assets of their U.S. tax obligations which could include a filing requirement and a U.S. tax liability. This Notice applies to all U.S....more

Offshore Tax Evasion Rounds Out IRS Annual “Dirty Dozen” For 2018

Fox Rothschild LLP on 4/4/2018

The Internal Revenue Service has issued a warning to taxpayers about avoiding taxes by hiding money or assets in unreported offshore accounts, a tax scam that remains on the annual “Dirty Dozen” for 2018. Offshore tax...more

IRS To Terminate The Offshore Voluntary Disclosure Program

Orrick, Herrington & Sutcliffe LLP on 3/23/2018

On March 13th, the Internal Revenue Service ("IRS") announced that the offshore voluntary disclosure program ("OVDP"), which was first launched in 2009 and modified several times, will close to new taxpayers after September...more

IRS Announces September 2018 End to Offshore Voluntary Disclosure Program

Blank Rome LLP on 3/21/2018

The Internal Revenue Service (“IRS”) announced it will close the highly successful Offshore Voluntary Disclosure Program (“OVDP”) on September 28, 2018, which presumably will be the final date for taxpayers to submit a...more

Annual Compliance Obligation Reminders

Vedder Price on 2/16/2018

Investment advisers registered with the U.S. Securities and Exchange Commission (“SEC”) or with a state (“Advisers”) as well as commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) registered with the...more

Paradise Papers, Panama Papers…. The Message is Clear: Report Offshore Accounts!

Foodman CPAs & Advisors on 11/22/2017

First, the Panama Papers, and now… the Paradise Papers. The Paradise Papers contain the names of approximately 31,000 US citizens, including entities, or persons with US addresses....more

Información tributaria de 36 países ya está en Colombia

Holland & Knight LLP on 10/13/2017

Por medio del comunicado de prensa No. 149 del 9 de octubre, la DIAN informó que en desarrollo de los Acuerdos de Intercambio de Información vigentes y de la Ley FATCA, recibió la información correspondiente al año 2016, de...more

Are you a Taxpayer identified by IRS for not Reporting Offshore Financial Assets?

Foodman CPAs & Advisors on 8/7/2017

Taxpayers with unreported foreign financial assets and income run the risk of having the Government determine if their conduct was willful or non-willful. The definition of “Willful" or "non-willful” in Taxpayer’s conduct...more

FBAR Penalty Amounts are in the “Best Judgement” of an IRS Examiner

Foodman CPAs & Advisors on 6/19/2017

The Report of Foreign Bank and Financial Accounts (FBAR) is not a tax form. Its filing is not required by the Internal Revenue Code. It is required by Title 31 of the Code of Federal Regulations. Title 31 is the Bank Secrecy...more

The High Cost of Being Noncompliant with the Internal Revenue Code

Holland & Knight LLP on 12/24/2016

The IRS currently offers the following five programs for noncompliant taxpayers: (i) the Offshore Voluntary Disclosure Program (OVDP), (ii) Streamlined Domestic Offshore Procedures, (iii) Streamlined Foreign Offshore...more

Upcoming FATCA Deadlines

Foley Hoag LLP on 6/27/2016

As noted in the Foley Adviser dated April 14, 2016, there are several upcoming FATCA-related deadlines, two of which are right around the corner: ..June 30, 2016: Foreign Financial Institution Due Diligence for...more

IRS Will Extend Some FATCA Transition Rules

Goulston & Storrs PC on 9/21/2015

In new Notice 2015-66 the IRS said it plans to amend FATCA regulations to reduce certain collateral restrictions on grandfathered obligations and extend the following transition rules: (1) the date for when withholding on...more

FATCA Update: Confidentiality of Information Transmitted to IRS; Announcement of “More Favorable” IGA Terms; and More IGAs

Blank Rome LLP on 7/31/2015

The month of July has seen several significant developments regarding implementation of the Foreign Account Tax Compliance Act (FATCA), which has been fully effective since July 1, 2014. First, the IRS Office of Chief...more

FATCA – It’s Here, It’s Not Going To Be Delayed And Action May Be Needed By April 25, 2014. Is Your Fund Ready?

Troutman Pepper on 3/14/2014

FATCA is the new form of 30% U.S. withholding tax that is applied to U.S. source income, such as interest and dividends paid by U.S. companies, starting as early as July 1, 2014 for payments made to non-U.S. entities that are...more

Foreign Account Tax Compliance Act › Foreign Financial Accounts

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