Foreign Bank Accounts

News & Analysis as of

IRS Issues Last-Minute FBAR Filing Reminder

With the June 30 deadline to file the FBAR form fast approaching, the IRS issued another reminder to taxpayers with bank accounts located outside of the United States. The IRS noted that during 2014, the total number of FBAR...more

IRS New Guidance Significantly Reduces Maximum FBAR Penalties

To moderate the draconian Foreign Bank and Financial Accounts (FBAR) violation penalties under Title 31 of the U.S. Code, the IRS just published guidance that significantly reduces willful and non-willful FBAR violations....more

June 30 Deadline: Foreign Financial Account and Asset Reporting Obligations

Do you maintain bank accounts outside the U.S.? Do you own any foreign financial assets, such as foreign stock or a loan to a foreign person? If you do, you should be aware that you may have extra reporting obligations to the...more

George Carlin and Erga Omnes: the Petrobras Bribery Scandal Expands

On this date in 2008 George Carlin died. If you grew up in the late 1960s or early 1970s and you had anti-parental or anti-establishment inklings, which of course all teenagers do, you knew about George Carlin. In the early...more

How Does the IRS Determine if Conduct is "Willful" or "Non-Willful"?

This Article is a guide for practitioners and taxpayers in deciding whether to apply for the streamline procedures of the IRS's Offshore Voluntary Disclosure Program ("OVDP"). The streamline procedures require a certification...more

New Option for Late FBARs – Just File It!

An often overlooked filing obligation is the annual June 30 requirement to file the FBAR form for taxpayers with foreign bank accounts aggregating over $10,000. Late FBARs are a consistent problem and the IRS has a long...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

Delinquent FBAR Reporting and How to Come Forward? Fact and Choice of Method Really Matter!!!

FBARS for 2014 are Due and MUST BE FILED by June 30, 2015 - There are three approaches to coming forward and filing delinquent FBAR's (Report of Foreign Financial Account). They are...more

IRS Reminds Taxpayers with Foreign Assets of Their FBAR/FATCA Obligations As Key Deadline Approaches

Today the Internal Revenue Service issued two public notices reminding taxpayers of their obligations to report foreign assets as the June 30 FBAR deadline fast approaches. Each notice referred to the extensive guidance...more

Didn’t File an FBAR? Don’t Panic

As I discussed in a prior blog post, if you have more than $10,000 in a foreign bank account, you are obligated to file Form 114 (commonly known as an FBAR). Failure to make this filing can result in significant civil...more

Two More Banks Reach Resolutions Under Justice Department’s Swiss Bank Program

On June 3, 2015, the Justice Department announced that two more Swiss banks, Rothschild Bank AG and Banca Credinvest SA, reached resolutions under the DOJ Swiss Bank Program. Yesterday’s announcement brings the total Swiss...more

BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement [Video]

Global tax enforcement is the number one priority of the U.S. authorities, and they are using their resources and tools in unprecedented ways to ensure that those who intentionally evade taxes are identified and brought to...more

Top 10 Foreign Bank Account Reporting (FBAR) Mistakes (And How to Fix Them)

While FBAR reporting rules are frequently misunderstood, US persons have several options to correct mistakes, before the government learns of the non-compliance. June 30th is the annual deadline for filing a Foreign...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

IRS Issues Internal FBAR Penalty Guidance To Ensure Consistency

Shortly before the annual June 30 FBAR filing deadline, the IRS issued penalty guidance for those that miss the foreign bank account reporting deadline. The purpose of the new penalty guidance is to improve the IRS’s...more

FATCA Compliance Deadline Reminder – Cayman Islands

Cayman Islands investment entities that have been classified as “Reporting Cayman Islands Financial Institutions” for purposes of FATCA should make every effort to enroll with the Cayman government by the April 30, 2015...more

Bad News About Unfiled FBARs, Another Indictment

A recent indictment by the United States Attorney's office in California illustrates the inter-relationship between curency transfer restrictions, (such as those involving Iran), foreign financial account reporting (the FBAR...more

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

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