Foreign Bank Account Report

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

Offshore Disclosure: What Needs To Be Disclosed? A Checklist

The following is a list of questions that should lead to the discovery of offshore assets, whether properly reported or not. If you answer yes to any of these questions, then you may have filing obligations and should seek...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

Is Mental Disease or Impairment a defense to “Willfulness” penalties for FBAR purposes?

In a pending civil penalty case in Florida the government puts forth its argument in clear language to describe what constitutes “willful” failure to file a Report of Foreign Financial Account (FBAR). In its Motion for...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

Must BitCoin Users file Reports of Foreign Bank Accounts (FBARs)?

A great deal of attention has been paid to BitCoin by the media, including the financial press. Among the reasons offered for using BitCoin is privacy and anonymity. However, a subtext in the rationale is that because of the...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

Beanie Baby Creator Avoids Jail Time, Pays Steep Penalties for Undisclosed Offshore Accounts

On January 14, 2014, Beanie Baby creator H. Ty Warner was sentenced to two years of probation and 500 hours of community service resulting from his guilty plea for tax evasion. In addition, Warner was required to pay...more

FinCEN Announces Extension for Certain FBAR Filers

Certain individuals having only signature authority over foreign financial accounts now have until June 30, 2015 to file the Report of Foreign Bank and Financial Accounts....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

FINRA Settles Administrative Proceedings Against Clearing Broker-Dealer For Failures to Comply with Anti-Money Laundering,...

The Financial Industry Regulatory Authority, Inc. (“FINRA”) issued an order (the “Order”) settling administrative proceedings against a clearing broker-dealer (the “Broker”), regarding various failures to comply with...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

Should Offshore Banks Share FBAR Penalties

Many participants in and out of the Offshore Voluntary Disclosure Program (OVDP) have concerns that the financial institutions who marketed or promoted secret account with tax evasion at its core are not paying their fair...more

FBAR Non-filers Beware of Global Information Exchange Agreements

At the most recent meeting of the Finance Ministers and Central Bank Governors on July 19 & 20, 2013 they said “We are committed to automatic exchange of information as the new, global standard and we fully support the OECD...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

Creator of Beanie Babies Pleads Guilty to Tax Evasion

H. Ty Warner, the creator of Beanie Babies pleaded guilty to offshore tax evasion today. Mr. Warner has agreed to plead guilty to a single count of tax evasion and to pay a $53 million FBAR penalty. Despite his cooperation...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

82 Results
|
View per page
Page: of 4