Foreign Bank Accounts

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

DOJ Announces First Non-Prosecution Agreement Under the Swiss Bank Program

On March 30, 2015, the U.S. Department of Justice (DOJ) announced that it reached the first non-prosecution agreement under the Swiss bank program with BSI, S.A. (BSI). BSI, one of Switzerland's ten largest banks, has agreed...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

Can A Form 1040 Income Tax Return Omission Lead to an Extended Statute of Limitations for an Estate Tax Return (Form 706) or...

Surprisingly, yes! At least according to the IRS. How so? Here’s at least one scenario where it is possible: An executor for a decedent’s estate files a final Form 1040 for the decedent. The executor does not report a...more

First bank resolution announced by DOJ: US taxpayers advised that time is running out to come forward

On March 30, 2015, the US Department of Justice announced the first non-prosecution agreement entered into by a Swiss bank pursuant to the Swiss Bank Program and advised US taxpayers with secret offshore bank accounts that...more

IRS Clarification on Non-Willful Conduct Certification for Streamlined Offshore Compliance Procedures: Revisions to IRS Forms...

Many U.S taxpayers are often surprised to discover that they have a U.S. tax reporting obligation on financial accounts or assets held overseas. Once they discover their obligation, there are a number of programs through...more

Gulliver’s Travels, Truth or Fiction?

There was once a man named Gulliver who traveled widely and wrote a book about his adventures called Gulliver’s Tales. During his first voyage, Gulliver is washed ashore after a shipwreck and finds himself a prisoner of a...more

"FATCA Finally Takes Effect, Subject to Transition Rules"

After several years of delays, the Foreign Account Tax Compliance Act (FATCA) finally took effect on July 1, 2014. Congress enacted FATCA as part of the Hiring Incentives to Restore Employment Act in 2010 to stop U.S....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 Announces That More Than 50,000 Have Enrolled In OVDP; Amnesty Program To Remain Open Indefinitely

Yesterday, the Internal Revenue Service unveiled its latest statistics on participation in its Offshore Voluntary Disclosure Program (OVDP), an amnesty program for taxpayers with undisclosed foreign bank accounts that has...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

Bank Leumi Enters Into DPA with U.S. Department of Justice

A major Israeli international bank admitted that it conspired to aid and assist U.S. taxpayers to prepare and present false tax returns to the Internal Revenue Service (IRS) by hiding income and assets in offshore bank...more

Highlights of Final Regulations for Reporting of Specified Foreign Financial Assets

The Treasury Department has issued final regulations relating to reporting of specified foreign financial assets on Form 8938. The highlights include...more

New Cyprus decrees further relax banking restrictions

The Republic of Cyprus issued new decrees on 8 December 2014. The new decrees provide further relaxation to banking restrictions, notably: Payments and/or transfers of funds abroad up to €2.000.000 (previously...more

FATCA Update: Treasury Clarifies Obligations of Participating FFIs to Report Pre-Existing Accounts

Earlier today, Treasury and the IRS issued yet another correcting amendment to the previously-issued regulations implementing the Foreign Account Tax Compliance Act (FATCA). FATCA become effective on July 1, 2014, and...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

At Her Majesty‘s Pleasure? Directors of ‘can pay, won‘t pay’ award debtors face the prospect of an extended stay in England should...

The grant by Males J of an order for the appointment of receivers by way of equitable execution in relation to foreign assets held by two arbitration award debtors, Unitech Limited (”Unitech”) and Burley Holdings Limited...more

FATCA Notebook: Former IRS Chief, Taxpayer Advocate Criticize FATCA; Switzerland Moves Toward Greater Transparency

First, former acting IRS Commissioner Steven Miller speaks out against FATCA and suggests that the benefits of the new information reporting regime imposed by FATCA may not outweigh its costs. An article published by...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

IRS Issues FATCA Fraud Alert

As part of its continuing efforts to combat the serious problem of identity theft, the Internal Revenue Service warned today that fraudsters have expanded their widening schemes to obtain identity information to foreign...more

What Financial Advisers and Accountants Should Know About Expanded IRS Streamlined Filing Compliance Procedures for U.S. Taxpayers...

The Internal Revenue Service (IRS) recently announced “major changes” to its offshore compliance programs, including the Streamlined Filing Compliance Procedures (Streamlined Procedures), the delinquent international...more

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