Foreign Bank Account Report

News & Analysis as of

Is Mental Incapacity a Defense to Tax Penalties and FBAR Penalties?

The Tax Crimes Handbook of the Office of Chief Counsel, Criminal Tax Division of the Internal Revenue Service defines "Willfulness” as follows: "[a] Willfulness is defined as the "voluntary, intentional violation of a...more

El FBAR y La Declaración de Impuestos Se Sincronizan

La presentación de la declaración de impuestos (el 15 de Abril para los individuos) y el formulario de FinCEN -Informe 114, conocido como FBAR (el 30 de Junio para todos los contribuyentes) no estaban alineadas, y no existía...more

The FBAR and Tax Return are now in Sync!

The filing of the tax return (April 15 for individuals) and Report FinCEN Form 114, known as FBAR (June 30 for all taxpayers) were not aligned, and that there wasn’t an extension available for the FBAR. This disconnect is...more

FinCEN Extends Filing Deadline for Certain FBAR Filers

Certain individuals who have only signature authority over foreign financial accounts now have until April 15, 2017 to file the Report of Foreign Bank and Financial Accounts....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

FBAR: 2015 Reports Due by June 30, 2016

Every U.S. person (including both individuals and entities, as discussed below) that had a financial interest in, or signature or other authority over, one or more foreign financial accounts during 2015 must electronically...more

Don’t Let The I.R.S. Define Your Conduct As Willful, or Else………

Something that most of us don’t realize is that Internal Revenue Service has stated that the taxpayer is responsible to learn IRS requirements within the historic U.S. framework of a voluntary reporting system. The IRS...more

Foreign Bank Account Reports Due June 30

U.S. Taxpayers who directly or indirectly controlled foreign financial accounts in 2015 are reminded that the deadline to file a Report of Foreign Financial Account (FBAR) FinCEN Form 114 is June 30. Taxpayers with unfiled...more

You Skipped OVDP, now the IRS has initiated an Audit

Since 2009, the Offshore Voluntary Disclosure Program (OVDP) has been available to Taxpayers who have foreign assets, foreign financial accounts, and foreign source income unreported for U.S. Income Tax and Bank Secrecy Act...more

As Panama Papers Illustrates, IRS Discovery of Undisclosed Assets Just a Matter of Time

As the recent leak of the "Panama Papers" reminded the world, some secrets don't keep well, particularly those related to undisclosed foreign assets. And once a person's identity is disclosed as a holder of undisclosed...more

Private Eyes They’re Watching You – Offshore Planning after the Panama Papers

Overview - If you have been reading my articles on JD Supra for a while, you will know that I love Afro-Cuban and Brazilian music. Nevertheless, the Hall and Oates song Private Eyes, is a more fitting song to describe...more

Swiss Cheese con Arroz con Pollo – Pondering Offshore Planning after the Panama Papers Scandal

Overview - It is an understatement to say that the state of affairs in the offshore landscape is in flux. The fallout from the recent scandal in Panama remains to be seen. The fall of the rich and famous may end up...more

Failure to Report Foreign Accounts is Illegal, IRS Warns

Maintaining a foreign bank or other financial account is not illegal. Such accounts are increasingly common, as the globe shrinks. However, in the case of U.S. citizens or residents (and certain non-residents), failing to...more

IRS Changes Streamlined Filing Compliance Procedures for Non-Willfulness Certification Forms

The Internal Revenue Service (IRS) recently modified the non-willfulness certification form that individual taxpayers must submit to enroll in the streamlined filing compliance procedures (SFCP). SFCP is a program offered by...more

Online Poker: A New Way to Bank?

In light of Tax Day (note that it’s on the 18th of April this year due to a holiday on the 15th) we want to point out a curious ramification from a federal case concerning online gambling, tax reports, and foreign...more

When Offshore Asset Protection Fails

What happens when The IRS attacks your offshore asset protection plan? The simple answer is you may face a variety of civil and criminal investigations and penalties. What constitutes an offshore asset protection plan?...more

FinCEN Proposes Revised FBAR Rules

On March 1, 2016, the Financial Crimes Enforcement Network (FinCEN) proposed rules that would revise and clarify certain provisions regarding the filing of Reports of Foreign Bank and Financial Accounts (FBAR). The rules, if...more

Reasonable Cause and Record Reconstruction

Individuals suffering from mental illness or the effects of substance abuse may have a "reasonable cause" for penalty relief. Example, an individual who is suffering from chronic drug dependency who may have been in and out...more

Proposed FBAR Regulations Expand Filing Exemption and Reporting Requirements

As reported in our prior client alerts, the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), must be filed by a U.S. person that holds a financial interest in, or signature or other authority over, a...more

Financial Services Weekly News - March 2016

Regulatory Developments - CFPB Now Accepting Complaints on Online Marketplace Lenders - On March 7, the Consumer Financial Protection Bureau (CFPB) announced two initiatives: it will now accept complaints from...more

Annual Estate Planning Newsletter: Part Five

Action Item: This is the fifth installment of our Annual Estate Planning Newsletter, and focuses on foreign matters. We urge you to review this installment to ensure that your 2016 estate and tax planning is in...more

FBAR Proposed Regulations Expand Both Filing Exemption and Reporting

On March 1, the Financial Crimes Enforcement Network (FinCEN) issued proposed regulations that revise and clarify certain provisions in the rules regarding the filing of Reports of Foreign Bank and Financial Accounts (FBAR)....more

Cross-Border Banking and Out-of-this-World Penalties - Dealing with the IRS when you have Foreign Bank Accounts

A United States citizen or resident that owns (or has signatory authority over) an account at a foreign bank with a value in excess of $10,000 annually must file a Report of Foreign Bank and Financial Account (or “FBAR”) with...more

DOJ Tax Division Chief Outlines Enforcement Priorities for 2016

In speech delivered on January 29, 2016, at the American Bar Association’s Tax Section Midyear Meeting, Acting Assistant Attorney General Caroline D. Ciraolo of the Justice Department’s Tax Division recapped her agency’s...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

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