Foreign Bank Account Report Income Taxes

News & Analysis as of

FBAR Deadlines Not as Close as You Think: New Tax Bill's Language Points to 2017 as Likely Timetable

Thank you for your interest in the 5th Annual IRS Hot Topic Seminar held in Jerusalem in July. In continuing our efforts to provide timely and extremely important updates on tax matters affecting U.S. citizens and green card...more

Do Recent FBAR Changes Indicate a Softening of the IRS’ Stance Toward Taxpayers with Foreign Financial Accounts?

Bring up the topic of FBARs (Report of Foreign Bank and Financial Accounts) with someone who has foreign financial accounts and the conversation will most likely take a nosedive. With an enforcement regime which can apply...more

A Welcome Change: Congress Finally Conforms FBAR and Tax Return Filing Deadlines

Last week Congress passed, and the President signed, a bill entitled “The Surface Transportation and Veterans Health Care Choice Improvement Act of 2015.” While this legislation was primarily directed at extending federal...more

Congress Sneaks in Some Important Procedural Tax Changes

On July 31, 2015, President Obama signed HR 3236, the "Surface Transportation and Veterans Health Care Choice Improvement Act of 2015." While you wouldn’t know it from the title, Congress included some important procedural...more

Foreign Citizen Living In the U.S.? Remember Your FBAR

If you are a foreign citizen that is considered to be a resident for U.S. income tax purposes, you need to be aware that your U.S. tax filing obligation is not limited to the income tax return. U.S. taxpayers (including...more

2014 Foreign Financial Account Reporting Requirements

U.S. citizens or residents who owned, directly or indirectly through an entity, beneficially or who had power of attorney/signature authority over one or more foreign financial accounts with an aggregate value exceeding...more

Delinquent International Information Tax Returns May Extend the Statute of Limitations on Your Entire Federal Tax Return

More and more, U.S. taxpayers are becoming aware of their federal tax reporting obligation for foreign financial accounts, interests and assets. With increased IRS enforcement, broader media coverage of international tax...more

What To Do If You Have Delinquent International Information Tax Returns

A U.S. taxpayer with international holdings and interests may not be fully compliant with U.S. tax reporting obligations even though they have currently reported all foreign source income on their annual tax return, filed...more

Foreign Account Holders: Don’t Forget to File Your FBARs by the June 30th Deadline

Now that the April 15th deadline has passed and tax season is over, most taxpayers can breathe a sigh of relief. At least for another year. For others with overseas financial accounts and interests, one more reporting hurdle...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

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

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

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

Part V - Minimizing Risk Of Criminal Prosicution By Meeting Requirements For A Voluntary Discover In IRM 9.5.11.9

Below is Part 5 of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures....more

Streamline Certification Advice

Effective July 1, 2014 new Streamline Procedures for voluntary disclosures may provide some taxpayers the opportunity to pay a substantially reduced or no penalty FBAR penalty depending upon whether they are domestic or...more

Part 3 – The Delinquent FBAR Submission Procedures

Below is Part 3 of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures....more

Part 2 - The IRS’ New 2014 Offshore Volunteer Disclosure Procedures

Below is Part 2 of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures. To view this Part, and all prior parts, in PDF format...more

June 30 Deadline Approaches for Mandatory E-File FBAR Reporting

2014 presents particular challenges with respect to FBAR, the Report of Foreign Bank and Financial Accounts, for certain U.S. persons with interests in or signature authority over assets exceeding $10,000 held outside the...more

IRS Eases Access to Offshore Voluntary Disclosure Programs

The changes give taxpayers who mistakenly failed to report foreign assets a simpler path back to tax compliance. On June 18, 2014, the Internal Revenue Service (IRS) announced major modifications to the terms of its...more

IRS Identifies ‘Attorneys-in-Fact’ as Potentially Required to File Under the Foreign Bank Account Reporting Rules

Most United States persons who have foreign financial accounts are aware that they must file an annual report to the Internal Revenue Service (IRS) with respect to these accounts. Less well known, however, is that individuals...more

IRS Announces Major Changes to OVDP

On June 18, 2014, the IRS announced major changes to the OVDP, including a major expansion of the so-called Streamlined Program and an increased penalties for taxpayers who held accounts at banks that are under criminal...more

Bitcoins Do Not Require FBAR Filing

I have been posting a lot of FBAR-related posts lately. Here’s one more. There has been a question whether owners of “bitcoins” and other virtual currencies that have non-U.S. aspects, are subject to annual reporting...more

IRS Unveils New Compliance Program

According to the Miriam Webster dictionary, credibility is defined as "the quality or power of inspiring belief." When IRS Commissioner John Koskinen took office, one of his many roles involved trying to restore the integrity...more

IRS Releases Bitcoin Guidance; May Have A Chilling Effect On Virtual Currency

Last week, the IRS released IRS Notice 2014-21 (the “Notice”), its first guidance on the income tax treatment of virtual currency, including, bitcoin. A copy of the notice can be obtained at...more

Virtual Reality: IRS Provides Guidance on the Treatment of Bitcoin and Other Virtual Currency Transactions

On March 25, 2014, the Internal Revenue Service (IRS) issued Notice 2014-21 (the Notice), which provides guidance regarding the tax treatment of Bitcoins and other virtual currency through a series of “frequently asked...more

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