News & Analysis as of

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

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

Are you an innocent spouse for FBAR purposes?

The U.S. Tax Court (Tax Court) has restated the basic principles for a person to obtain “innocent spouse” relief from tax assessments. The criteria are as follows...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

FBAR and Form 8938 Assistance Provided by Treasury

There are a multitude of information returns that United States taxpayers may need to file if they own foreign assets or have foreign investments. Two of these forms are the FBAR (Foreign Bank Account Report) and Form 8938...more

FBAR Update

The Report of Foreign Bank and Financial Accounts (FBAR) can no longer be filed on TDF 90-22.1, and must be e-filed on Form 114. This alert summarizes developments involving FBAR e-filing and signature authority. They are...more

FBAR E-Filing and Signature Authority: What You Need to Know

Much has been written about the IRS's dogged pursuit of taxpayers with unreported foreign accounts. These accounts are reported on the Report of Foreign Bank and Financial Accounts (FBAR) when a taxpayer has a financial...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

Criminal FBAR Prosecutions Underscore Importance of IRS Offshore Voluntary Disclosure Program

According to statistics compiled by Jack A. Townsend, author of the Federal Tax Crimes Blog, nearly 130 individuals have been charged with maintaining and failing to report offshore bank accounts, or enabling those who do. ...more

The Qualified Quiet Disclosure: Operating Outside Of The IRS Offshore Voluntary Disclosure Initiative

Individuals with previously undisclosed foreign assets and/or income have a variety of options to become compliant with the IRS, with two avenues for resolution being the most common: Qualified Quiet Disclosure and the...more

American Pleads Guilty to Hiding Money in Israeli Bank Accounts

Tax Analysts Tax Notes is reporting that David Raminfard of Los Angeles pleaded guilty on November 4, 2013, in federal court to one count of conspiracy to defraud the United States (Klein conspiracy). ...more

IRS Penalty Avoidance-Reliance on Professionals

The U.S. Supreme Court, in Knappe, is being asked to revisit its decision in a case where it stated the standard for what constitutes reasonable cause based upon reliance on advice of professionals. In Boyle the Court...more

Arizona Businessmen Receive Lenient Sentences For Stashing Millions in Secret Swiss Accounts

Bloomberg BNA is reporting that two prominent Phoenix businessmen were each sentenced to 10 months in prison for their roles in a scheme to stash more than $8 million in secret offshore Swiss bank accounts and for not...more

IRS Requiring Taxpayers to File FBARs Electronically Raises Concerns About Delinquent Filing and Offshore Voluntary Disclosure...

In recent years, the United States government has intensified its efforts to collect taxes on income generated by offshore bank accounts and financial holdings. A key tool in these enforcement efforts is a provision under...more

Fiduciary Liability and Offshore Assets

Fiduciaries, like trustees and conservators, may face personal liability for wrongful acts in administering estates. Among the liabilities that a fiduciary may face is to the IRS for wrongful distributions such as those made...more

California Man Pleads Guilty to Hiding Money in Israeli Banks

Tax Analysts Tax Notes is reporting that Aaron Cohen of Encino, Calif., pleaded guilty today in the U.S. District Court for the Central District of California to conspiracy to defraud the United States....more

Willful Blindness-the Ostrich syndrome

Often taxpayer’s will claim that the did not know of their obligation to file a Report of Foreign Bank or Financial Account known as an FBAR. When pressed the fact pattern often begins with a statement like my tax advisor...more

IRS Seeking 50% x 4 Penalties In FBAR Nonreporting Case

Taxpayers are required to disclose their ownership interests in foreign bank and financial accounts by filing a Form TD F 90-22.1, ...more

Taxpayer Advocate Continues to Criticize Offshore Voluntary Disclosure Programs

In an update to her December 2012 report, the Taxpayer Advocate has noted that the IRS still has not provided reasonable options for “benign actors”, or taxpayers who inadvertently violated the rules for reporting foreign...more

Ropes & Gray’s Private Investment Fund Update: June 2013

Highlights - SEC Updates Form PF "Frequently Asked Questions" - The SEC recently released updated "Frequently Asked Questions" relating to Form PF that, among other things, clarified how Form PF filers should...more

No Records is Not an Acceptable Excuse

Often taxpayers who have not filed Reports of Foreign Bank or Financial Accounts (FBAR’s) will claim that they do not have records of their offshore accounts, because the accounts are maintained by third parties. In many...more

FBAR Filing Deadline Imminent

Reports Due Before the End of June - Every U.S. person that had a financial interest in, or signature authority over, a foreign financial account during 2012 must file U.S. Treasury Form TD F 90-22.1, Report of Foreign...more

Department of Justice Sues Taxpayer to Collect $3.5 Million in FBAR Penalties, Possibly Putting Dutch Bank ABN AMRO's Swiss...

Carl R. Zwerner of Miami, Florida, is facing nearly $3.5 million in civil penalties for failing to report a Swiss bank account, according to a lawsuit filed by the Justice Department (United States v. Zwerner, S.D. Fla., No....more

Deadline To File FBARs Quickly Approaching

There is absolutely nothing wrong with having a foreign bank account. The problem comes along when the existence of the account is not disclosed and income associated with the account is not reported....more

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