Foreign Bank Account Report

News & Analysis as of

Tax Day Has Passed, But Don’t Forget June 30th!

Now that April 15th has passed, you might be thinking that you are done with tax filings for the year. But, if you have any foreign bank accounts or financial assets overseas, you may be required to file a Form 114 (commonly...more

Taxpayer Advocate Recommends Ways for IRS to Simplify Foreign Asset Reporting

The National Taxpayer Advocate made three specific recommendations to the IRS to try to simplify the process for reporting foreign assets. For several years the National Taxpayer Advocate has complained that the disclosure...more

No Place to Hide – FATCA Reporting Begins

Foreign asset reporting requirements are nothing new.  US taxpayers have long been required to report worldwide income, and the FBAR filing requirements have been around since the 1970s.  ...more

2014 Tax Reporting

Don’t Forget About Your Foreign Financial Assets - U.S. citizens, resident aliens and certain non-resident aliens who held any interest in “specified foreign financial assets” at any point during 2014 may be required...more

Bitcoin and the Like: Tax Considerations

Virtual currency is a new, untested, and unregulated asset. The Internal Revenue Service (IRS) defines “virtual currency” as a digital representation of value that functions as a medium of exchange, a unit of account, and/or...more

Coming to America (for Business) - Using the L1 Visa as an Alternative to EB 5

Overview - As a long term veteran of the financial services industry, I have learned that in many cases, people do not “buy” a product or service but instead are “sold”” the product or service that the advisor is...more

Financial Services Weekly News Roundup - February 2015 #4

FDIC Study Shows Branch Banking Has Staying Power: Has your smartphone displaced your bank? According to an FDIC study released on February 19, traditional brick-and-mortar offices are maintaining their primacy, despite...more

California Physician Pleads Guilty to Failing to File FBAR for Bank Leumi Account

On February 2, 2015, Baruch Fogel, a California doctor, pleaded guilty in the U.S. District Court for the Central District of California to one count of willful failure to report the existence of a foreign bank account on a...more

IRS Clarifies Requirements for Establishing Non-Willful Conduct in Offshore Disclosure Cases

Voluntary disclosure programs exist for taxpayers that are not in compliance with their tax and information reporting obligations with respect to foreign bank accounts and assets. The Internal Revenue Service (IRS) recently...more

FinCEN Again Extends Deadline for Certain FBAR Filers

Certain individuals who have only signature authority over foreign financial accounts now have until June 30, 2016 to file the Report of Foreign Bank and Financial Accounts....more

2015 Estate and Tax Planning

Blank Rome’s annual estate planning newsletter discusses certain concepts and techniques that we hope may be of interest to our clients and friends....more

IRS Updates Streamlined Certification Forms; Narrative Explanation Is Mandatory

The Internal Revenue Service has recently updated the certification forms required to be filed by taxpayers seeking to avail themselves of the Streamlined Filing Compliance Procedures. The streamlined program was...more

When Do Non-U.S. Citizens Pay Income Tax And Report Foreign Financial Accounts?

In a series of Frequently Asked Questions releases December 31, 2014, The Congressional Research Service provides some guidance on when non-U.S. citizens may be subject to U.S. income taxes....more

Should You Participate in the IRS Offshore Voluntary Disclosure Program?

2014 marked a significant increase in the enforcement efforts by the IRS and Department of Justice against non-compliant U.S. taxpayers who failed to report their off-shore bank accounts and earnings.  Grand Jury proceedings...more

The Death Of Hidden Offshore Accounts

The future for offshore tax planning, also known as “aggressive tax planning” is likely to be limited to if not curtailed by the global exchange of information agreement signed in October, 2014 by 51 countries and growing....more

Financial Services Weekly News Roundup - December 2014 #3

Amendment to Swaps Push-out Provision of Dodd-Frank: Section 630 of the recently passed Consolidated and Further Continuing Appropriations Act, 2015 (“Omnibus Spending Bill” – see p. 249) amends Section 716 of the Dodd-Frank...more

Happy Holidays – There is a Budget Deal, Now Look Out

The just passed budget deal known as Consolidated and Further Continuing Appropriations Act, 2015 contains a reduction in funding for the IRS. The Bill provides a reduction in total IRS funding of $346 million less than last...more

Informal Surrender Of Green Card Doesn’t Work

The recent decision of the U.S.Tax Court, in Gerd Topsnik, (2014) makes it clear that an “informal” surrender of a Green Card, while recognized under immigration laws is not recognized for tax purposes....more

Wegelin & Co. Account Holder Sentenced to Prison Term

On October 30, 2014, a federal judge in Manhattan handed down a three-month prison sentence to an individual who maintained more than $1 million in a secret bank account at Wegelin & Co. in Switzerland. Viktor Kordash, of...more

IRS Modifies Offshore Filing Procedures

The IRS has issued FAQs relating to the new streamlined procedures for offshore compliance, and for Delinquent International Information Return Submission Procedures....more

Treasury Makes Life Easier for Holders of Canadian Retirement Account Interests

Treasury automates the process for U.S. taxpayers making an election to defer taxation of Canadian RRSPs and RRIFs and to eliminate some information reporting requirements as to those accounts. ...more

Forensic Accountant and Certified Fraud Examiner Pleads Guilty to Concealing UBS Account

On October 3, 2014, according to a U.S. Attorney’s Office press release and court records, Howard Bloomberg, a forensic accountant and certified fraud examiner, pleaded guilty to one count of failure to file an FBAR reporting...more

DOJ Continues to Prosecute Those Who Fail to File FBARs to Disclose Offshore Accounts

Howard Bloomberg, a forensic account and certified fraud examiner of Atlanta, Georgia, pleaded guilty on Friday to failing to file a Foreign Bank Account Report (FBAR) for the year 2008. Mr. Bloomberg opened a bank account at...more

Offshore Voluntary Discloure; Is it too late

September 15, 2014 is an important for taxpayer who maintained accounts at any of 106 Swiss banks (participating banks) that are participating in the Department of Justice non-prosecution program. Here is why....more

Streamline Procedure-What does non-willful mean?

In order to use the Streamline Procedures (domestic and non-resident) a U.S. taxpayer must certify that their failure to file a timely FBAR was non-willful. The term non-willful is essentially a “clinical” conclusion based...more

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