Foreign Bank Accounts

News & Analysis as of

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

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

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?

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

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

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

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?

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?

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)?

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?

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

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?

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?

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

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

Sonhos Interrompidos - Como uma não conformidade tributária pode destruir o Sonho Americano de imigrantes não registrados - Parte...

Panorama - A Parte I desta série teve enfoque no pesadelo e problema imprevisto de declarações de impostos não apresentadas para imigrantes não registrados. As consequências de "empurrar o problema com a barriga"...more

Cayman Islands FATCA Compliance Deadlines Extended Again

The Cayman Islands announced the further extension of the 2016 registration and reporting deadlines for U.S. FATCA and U.K. FATCA (also known as U.K. CDOT), as follows...more

Broken Dreams - How Tax Non-Compliance Can Destroy the American Dream of Undocumented Immigrants - Part 2

Part I of this series focused on the unforeseen nightmare and problem of unfiled tax returns for undocumented immigrants. The consequences of “kicking the can down the road”, will have significant legal and financial...more

New Jersey Man Prosecuted for Funneling Campaign Contributions from Foreign Source

Much of the U.S. media overlooked a Bill of Information filed in United States District Court in New Jersey on June 29. The information charged Bilal Shehu, an Albanian immigrant, with unlawfully funneling $80,000 from a...more

The Administrative Procedure Act - Challenging FBAR Penalties

Over the past 10 years, thousands of U.S. taxpayers with a wide variety of circumstances have been forced to pay extraordinarily high penalties for failure to disclose foreign bank accounts. For years, tax experts said that...more

¿Sabía usted que el IRS puede presentar una "Declaración de Impuestos Sustituta” basado en la información del Reporte FATCA?

¿Sabía usted que bajo el Código de Rentas Internas EE.UU, Sección 6620, si un contribuyente no presenta a tiempo la declaración de impuestos de los EE.UU., el IRS está autorizado a preparar y presentar una declaración de...more

Did You Know That the IRS May File a “Substitute for Return” from FATCA Report Account Holder Information?

Did you know that, under Internal Revenue Code, Section 6620, if a taxpayer does not timely file a U.S. tax return, the IRS is authorized to prepare and file a U.S. tax return for that taxpayer based on the knowledge that it...more

Foreign Bank Account Reporting and Employment Tax Enforcement: Ronn Owens interviews Steve Moskowitz [Audio]

Ronn Owens interviewed Steve Moskowitz on June 28 and they discuss IRS priorities, including Foreign Bank Account Reporting and Employment Tax Enforcement. Steve and Ronn further discuss the history of individual tax rates...more

Hong Kong & Singapore: Awaiting a New DOJ Tax Program for Asian Banks?

As the Department of Justice is wrapping up its prosecution of over a dozen Swiss banks, federal prosecutors and IRS special agents are analyzing a treasure trove of previously undeclared taxpayer account information that...more

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