Foreign Bank Accounts

News & Analysis as of

Bitcoin Reportability and Taxation

June 30 is the deadline for taxpayers with a connection to foreign financial accounts to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR). As this is the first year in which all FBARs must be...more

DOJ Secures Verdict in Excess of $2 Million for Failure to File FBARs

On Wednesday, May 28, 2014, a jury in Miami issued a verdict against a taxpayer for $2.2 million in fees, interest, and civil penalties for willfully failing to file foreign bank account reports (FBARs) for his Swiss bank...more

Latest Cyprus decrees relaxing restrictive measures in banking

The Republic of Cyprus issued new decrees on 2 June 2014 which provide further relaxation of restrictive measures, including abolishing restrictions on the opening of new bank accounts. ...more

Will the Zwerner FBAR Fine Pass Constitutional Muster?

Last week, a federal jury in Miami found that Carl Zwerner had willfully failed to disclose his foreign bank account to the Treasury Department for calendar years 2004, 2005 and 2006. Zwerner now potentially owes the United...more

Swiss Bank Pleads Guilty In Alleged Tax Evasion Conspiracy

On May 19, the DOJ announced that a Swiss bank pleaded guilty and entered into agreements with federal and state regulators to resolve a multi-year investigation into the bank’s alleged conspiracy to assist U.S. taxpayers in...more

Getting a Green Card Subjects Noncitizens to U.S. Foreign Bank Account Reporting Requirements

A resident or citizen of a country other than the United States who obtains lawful permanent resident status in the United States, often referred to as a “green card,” becomes a resident of the United States for U.S. income...more

Court Rules U.S. Banks Must Disclose Nonresident Bank Account Information

As a result of a court decision last week, issued by the District Court in the District of Columbia U.S banks will be required to report interest earned on accounts held be non-resident aliens if the interest earned is $10.00...more

Beanie Babies Creator Seeks Probation for $107 Million UBS Account

The Chicago Tribune reports that Beanie Babies creator Ty Warner, who pleaded guilty last year to one of the largest tax frauds in Chicago-area history, has asked the federal court to sentence him to probation. His sentencing...more

Guide to the British Virgin Islands Approved Manager Regime

This guide provides an overview of the British Virgin Islands’ Approved Manager regime. The regime came into effect on 10 December 2012 with the Investment Business (Approved Managers) Regulations, 2012 (the “Regulations”)...more

Raminfard Guilty Plea Highlights Complexity Of International Tax Compliance, Seriousness Of Violations, Importance Of IRS Offshore...

Los Angeles Businessman, David Raminfard, pleaded guilty on November 4th, 2013 in the Federal District Court in Los Angeles to conspiring to defraud the United States, the Justice Department and Internal Revenue...more

International Tax News - November 2013

US-SWISS VOLUNTARY DISCLOSURE PROGRAM: DEADLINES ARE LOOMING – SWISS BANKS NEED NOT PANIC, BUT MUST ACT SWIFTLY AND THOUGHTFULLY - The recently announced voluntary bank disclosure program between Switzerland and the...more

Voluntary Disclosures Lead to John Doe Summonses for Information about U.S. Accounts at Zurcher Kantonalbank and Bank of...

In a sign that the U.S. government continues to aggressively seek information on U.S. taxpayers with non-U.S. bank accounts, the government announced on November 12, 2013, that it had obtained a court order authorizing the...more

US Allows Swiss Banks With Undisclosed Accounts To Wipe the Slate Clean

United States Department of Justice issues further information on amnesty program for Swiss banks, including details on the selection of an Independent Examiner. On November 5, 2013, United States Department of Justice...more

U.S. Department of Justice Awaits Swiss Banks’ Voluntary Disclosure of Banking Activities

The U.S. Department of Justice (“DOJ”) established a Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (the “Program”) on August 29, 2013. The Program is intended to facilitate a resolution with the...more

Leavers are targets of Offshore Tax Enforcement

Leavers are those U.S. taxpayers who have undeclared offshore financial accounts and who move those accounts from one bank to another, often moving to other countries in the hope of avoiding disclosure of the account to U.S....more

Voluntary Disclosure Program for Swiss Banks?

Bloomberg/BNA is reporting that the DOJ announced today a program for Swiss banks to reveal tax information in return for nonprosecution agreements. The U.S. Department of Justice announced a program Aug. 29 to get Swiss...more

So, You inherited an unreported offshore account, now what!

There may have been a time when inheriting an unreported offshore financial account was not problematic; but not today. The executor/trustee of the estate of the decedent has fiduciary responsibility to IRS and faces personal...more

Decrees 19 and 10 from Cyprus

The Republic of Cyprus issued new decrees on 2 August 2013 pertaining to the relaxation of restrictive measures. Legal updates regarding these decrees, from Harneys' Cyprus Banking Group, are below....more

Willful Blindness-the Ostrich syndrome

Often taxpayer’s will claim that the did not know of their obligation to file a Report of Foreign Bank or Financial Account known as an FBAR. When pressed the fact pattern often begins with a statement like my tax advisor...more

Taxpayer Advocate Continues to Criticize Offshore Voluntary Disclosure Programs

In an update to her December 2012 report, the Taxpayer Advocate has noted that the IRS still has not provided reasonable options for “benign actors”, or taxpayers who inadvertently violated the rules for reporting foreign...more

Mandatory Electronic Filing for FBARs Effective July 1, 2013.

June 30, 2013 is the filing due date for 2012 “FBARs,” also known as Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts. If there is a non-willful failure to file, the penalties are up to $10,000. If there is...more

FBAR Filing Deadline Imminent

Reports Due Before the End of June - Every U.S. person that had a financial interest in, or signature authority over, a foreign financial account during 2012 must file U.S. Treasury Form TD F 90-22.1, Report of Foreign...more

Department of Justice Sues Taxpayer to Collect $3.5 Million in FBAR Penalties, Possibly Putting Dutch Bank ABN AMRO's Swiss...

Carl R. Zwerner of Miami, Florida, is facing nearly $3.5 million in civil penalties for failing to report a Swiss bank account, according to a lawsuit filed by the Justice Department (United States v. Zwerner, S.D. Fla., No....more

The 2012 FBAR Filing Deadline is June 30, 2013

U.S. taxpayers with foreign accounts whose aggregate value exceeded $10,000 at any time during 2012 must file Treasury Department Form TD F 90-22.1 (Report of Foreign Bank and Financial Accounts) with the Treasury Department...more

Deadline To File FBARs Quickly Approaching

There is absolutely nothing wrong with having a foreign bank account. The problem comes along when the existence of the account is not disclosed and income associated with the account is not reported....more

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