News & Analysis as of

International Tax Compliance Update: Renouncing U.S. Citizenship to Avoid Taxes: Is It Worth It?

As we have reported previously in recent years the United States has intensified its efforts to force United States persons to disclose assets they hold and income they earn abroad. Two prominent examples of these efforts are...more

Offshore Tax Enforcement Update: IRS Unveils Major Changes to Voluntary Disclosure Program

Since the 1970s, U.S. taxpayers with foreign banks accounts have been required to annually report their foreign bank account information to the Department of Treasury on a Report of Foreign Bank and Financial Accounts...more

June 30 Deadline Approaches for Mandatory E-File FBAR Reporting

2014 presents particular challenges with respect to FBAR, the Report of Foreign Bank and Financial Accounts, for certain U.S. persons with interests in or signature authority over assets exceeding $10,000 held outside the...more

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

International Tax Compliance Update: IRS Hints at Coming Changes for Certain OVDP Filers

Remarks on Monday by John Koskinen, the Commissioner of Internal Revenue, indicate that the IRS is close to conceding to outside pressure to more clearly distinguish between Offshore Voluntary Disclosure Program (OVDP) filers...more

FBAR Penalty to Face Excessive Fines Clause Test

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

The Taxman Cometh for US Holders of Foreign Bank Accounts

U.S. citizens and residents with unreported assets abroad may be feeling a steady increase of pressure these days. The July 1, 2014 effective date of the Foreign Assets Tax Compliance Act (FATCA) is looming. The number of...more

FATCA Update: As Additional Countries Agree to Share International Tax Information, Hiding Assets Abroad becomes Increasingly...

In recent years the United States has increasingly amplified the pressure on United States persons to disclose assets they hold and income they earn abroad, especially relating to offshore financial accounts. Two prominent...more

Indicted Banker May Provide Valuable Leads

The following is an excerpt from a press release issued April 30, 2014 by Department of Justice, Tax Division (DOJ) announcing the indictment of a former senior officer of the Beverly Hills branch of an Israeli bank. The...more

FBAR and Form 8938 Assistance Provided by Treasury

There are a multitude of information returns that United States taxpayers may need to file if they own foreign assets or have foreign investments. Two of these forms are the FBAR (Foreign Bank Account Report) and Form 8938...more

FBAR Update

The Report of Foreign Bank and Financial Accounts (FBAR) can no longer be filed on TDF 90-22.1, and must be e-filed on Form 114. This alert summarizes developments involving FBAR e-filing and signature authority. They are...more

FBAR E-Filing and Signature Authority: What You Need to Know

Much has been written about the IRS's dogged pursuit of taxpayers with unreported foreign accounts. These accounts are reported on the Report of Foreign Bank and Financial Accounts (FBAR) when a taxpayer has a financial...more

California Man Pleads Guilty to Hiding Money in Israeli Banks

Tax Analysts Tax Notes is reporting that Aaron Cohen of Encino, Calif., pleaded guilty today in the U.S. District Court for the Central District of California to conspiracy to defraud the United States....more

U.S. Department of Treasury Mandates E-Filing of FBAR

Any Report of Foreign Bank and Financial Accounts (IRS Form TD F 90-22.1), the so-called “FBAR,” filed on or after July 1, 2013, must be submitted electronically. Any U.S. citizen or U.S. resident with more than $10,000 U.S....more

FinCEN Introduces New Form For Authorizing FBAR Filing By Spouses And Third Parties

On July 29, FinCEN released a new form for filers who submit Reports of Foreign Bank and Financial Accounts (FBARs) jointly with spouses, or who wish to submit them via third-party preparers. ...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

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

Foreign Banks Subject to U.S. Law

The U.S. Department of Justice (DOJ) has made it clear that it will continue an aggressive practice of prosecuting foreign banks and bank personnel that have materially aided U.S. taxpayers in hiding money offshore. The most...more

As Foreign Banks May Disclose U.S. Depositors, Foreign Account Holders Should Consider IRS OVDI Program

In December, Bank Leumi le-Israel BM issued a letter notifying its U.S. account holders about the IRS Offshore Voluntary Disclosure Initiative (the OVDI). The IRS OVDI is a type of amnesty program under which U.S. citizens...more

Must You Produce Records of Offshore Accounts?

A Petition to the U.S.Supreme Court may result in the Court deciding whether a taxpayer who has a previously unreported foreign financial account must produce records of the account in a criminal proceeding in spite of the...more

FBAR Filing Deadline Further Extended to June 30, 2014 for Certain Employees and Officers with Signature Authority Over Foreign...

Generally, each U.S. person who has a financial interest in, or signature authority over, one or more foreign financial accounts during a calendar year is required to report those accounts to the Internal Revenue Service...more

FinCEN Extends FBAR Filing Deadline

On December 26, FinCEN issued Notice 2012-2 to extend the deadline for certain filers to submit the Report of Foreign Bank and Financial Accounts (FBAR). FinCEN has extended this deadline several times in the past and the...more

FinCEN Announces Third Extension for Certain FBAR Filers

Certain individuals having only signature authority over foreign financial accounts now have until June 30, 2014, to file the Report of Foreign Bank and Financial Accounts. ...more

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