News & Analysis as of

Foreign Bank Accounts

Developing a Strategy to Fight FBAR Penalties

by Carlton Fields on

Since 2009, the number of FBAR penalties imposed for failures to report foreign bank accounts and the size of the penalties have both increased dramatically. Originally published in The Tax Advisor....more

New Due Date for “FBAR” Filings - Report of Foreign Bank and Financial Accounts now due on Tax Day, with auto-extension for six...

Federal law requires U.S. citizens and resident aliens to report world-wide income, including income from foreign trusts, bank and securities accounts. In addition to attaching Schedule B to their tax returns disclosing...more

Two Important New International Tax Filings

by Charles (Chuck) Rubin on

While not the only international reporting changes that are occurring, there are two significant ones that apply for the current filing season for 2016 returns. First is the FBAR, which reports interests in foreign...more

IRS Agent Discusses the Look-Back Period for Filing Delinquent International Information Returns

We represent a client who may need to file delinquent international information returns under the IRS Delinquent International Information Return Submission Procedures. These procedures invite taxpayers who meet the...more

2016 Foreign Bank Account Reports: New Filing Deadline

The U.S. government continues to pursue aggressively individuals and businesses for the failure to report foreign accounts and other non-U.S. assets. In particular, and with limited exceptions, all U.S. individuals and...more

Stay out of TROUBLE: Make sure your CPA is asking you the right QUESTIONS regarding Foreign Accounts!

by Foodman CPAs & Advisors on

US International tax is complicated. It often overwhelms US Taxpayers. That is why an international tax specialist CPA is the best choice for the work. Nonetheless, many Taxpayers seek the help of tax return preparers...more

NBU cancels certain individual licenses for individuals-residents of Ukraine

by Dentons on

On 23 February 2017 the National Bank of Ukraine (NBU) amended its regulations whereby it revisited the legal regime for placement money on foreign accounts and making foreign investments by individuals-residents of Ukraine....more

New Filing Date for Foreign Bank Account Return

If you have a foreign bank account (or signatory authority on a foreign bank account), you are required to file a Form 114 (commonly called an FBAR) if at any point during the calendar year the combined balance in all of your...more

Automatic exchange of information and insurance companies - a question of compliance

by Hogan Lovells on

Automatic exchange of information (AEOI) regimes, primarily aimed at curbing tax avoidance through the use of foreign accounts and investment platforms, have recently become a global trend, starting with the adoption of the...more

New Extended Due Dates for Foreign Bank Account Reports (FBAR)

by McNair Law Firm, P.A. on

All U.S. citizens and permanent residents are required to annually file a U.S. income tax return reporting their worldwide income from all sources. Additionally, U.S. citizens and permanent who have an interest in or...more

Reminder: FBARs Due in April Starting This Year

by Charles (Chuck) Rubin on

Until now, the Reports of Foreign Bank and Financial Accounts (FBAR) for foreign financial accounts was due on June 30 of each year, for purposes of reporting accounts for the preceding calendar year....more

Why are Americans Working Abroad Giving Up Citizenship?

by Ronald Shapiro on

Many Americans working abroad are renouncing their citizenship because of tax requirements imposed by U.S. tax laws. For Illinois residents employed overseas, an immigration lawyer in Chicago can explain tax laws that have an...more

FBAR Filing Deadline Extended for Certain Filers

by Proskauer Rose LLP on

On December 16, 2016, FinCEN issued Notice 2016-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain individuals with signature or other authority over...more

Filing Deadline Extended for Certain FBAR Filers

by Morgan Lewis on

Certain individuals who have only signature authority over foreign financial accounts now have until April 15, 2018 to file the Report of Foreign Bank and Financial Accounts....more

New York’s high court finds jurisdiction over foreign bank on basis of correspondent bank account activity

by DLA Piper on

In a ruling that three dissenting judges warned would “have grave implications for correspondent banking relationships,” New York’s Court of Appeals has reinstated claims against a Swiss bank after concluding that its alleged...more

¿Sabe usted el propósito de los Procedimientos de Presentación de Cumplimiento Racionalizados?

by Foodman CPAs & Advisors on

Procedimientos Racionalizados de Presentación de Cumplimiento (Streamlined Filing Compliance Procedures) es una de las opciones disponibles para los contribuyentes Estadounidenses con activos e ingresos financieros...more

Do you know the purpose of the Streamlined Filing Compliance Procedures?

by Foodman CPAs & Advisors on

Streamlined Filing Compliance Procedures (Streamlined) is one of the options available for US Taxpayers with unreported foreign financial assets and income. It is intended for the Taxpayers that have acted non-willfully. ...more

¿Sabe usted por qué y cómo entrar en el Programa de Divulgación Voluntaria de Cuentas en el Extranjero (OVDP)?

by Foodman CPAs & Advisors on

A través del Programa de Divulgación Voluntaria de Cuentas en el Extranjero (OVDP – Offshore Voluntary Disclosure Program), el IRS permite a los Contribuyentes que no están en cumplimiento intentionalmente revelar las cuentas...more

Do you know why and how to make an Offshore Voluntary Disclosure?

by Foodman CPAs & Advisors on

Through its Offshore Voluntary Disclosure Program (OVDP), IRS permits noncompliant taxpayers to disclose Willfully unreported offshore accounts and related income. The “key” word for OVDP is Willful. Unlike the Streamlined...more

Reckless Indifference Is Enough For Willfullness Finding For Puroses Of FBAR Nonfiling Penalties

by Charles (Chuck) Rubin on

A husband and wife had an accounting in Switzerland at UBS AG, into which they deposited commissions from camera sales and also directed some of their international customers to make deposits. In 2007, the tax year at issue,...more

Cuando FATCA y los Programas de Amnistía Fiscal se cruzan, ¿será demasiado tarde para los contribuyentes Estadounidenses?

by Foodman CPAs & Advisors on

Instituciones Financieras extranjeras (FFIs) y las autoridades fiscales de los países anfitriones le han proporcionado al IRS con una segunda ronda de informes de información sobre cuentas financieras mantenidas por los...more

When FATCA and Tax Amnesty Programs intersect, will it be too late for US Taxpayers?

by Foodman CPAs & Advisors on

Foreign Financial Institutions (FFIs) and host country tax authorities have provided IRS with a second round of information reports on financial accounts held by US Taxpayers. This exchange of information is automated and...more

$100 Million FBAR Penalty - Ouch

by Charles (Chuck) Rubin on

Taxpayers who fail to file Reports of Foreign Bank and Financial Accounts (FBARs) disclosing their non-U.S. accounts can suffer a 50% penalty on the balance of the unreported accounts. In one of the largest penalties I have...more

[Webinar] U.S. Tax and Estate Planning for Foreign Persons - Meritas Capability Webinar - September 27th - 1:00p.m. U.S. CDT

Many successful people come to the United States from other countries, either permanently or on study or work assignments that are intended to last just for a few years. These people may earn income in the United States and...more

Pre-immigration and Non-U.S. Resident Planning

Foreign individuals who intend to permanently reside in the U.S., or do not intend to reside in the U.S. but intend to own U.S. property, need considerable legal and tax planning. The definition of “U.S. property” for...more

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