Foreign Financial Accounts

News & Analysis as of

FinCEN Proposes Anti-Money Laundering and Suspicious Reporting Rules for Registered Investment Advisers

On August 25, 2015, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed rules that would require registered investment advisers to adopt anti-money laundering (AML) programs and report...more

Snowden is Only Part of the Disclosure Story

Edward Snowden may have brought attention to telephonic (voice and data) intelligence agencies both U.S and others, but I speculate that his revelations most likely have not changed the bulk of non-criminal or terrorist...more

Bad Bad, Bad Penalty, Bad OVDP Policy

There are now 50 foreign financial institutions on the IRS list of "bad banks" The list is published at the following link...more

IRS Will Extend Some FATCA Transition Rules

In new Notice 2015-66 the IRS said it plans to amend FATCA regulations to reduce certain collateral restrictions on grandfathered obligations and extend the following transition rules: (1) the date for when withholding on...more

Giving Up U.S. Citizenship - Estate and Gift Tax Traps

It may be a common misunderstanding that a U.S. citizen or permanent resident (Green Card holder) can give up their citizenship or surrender their Green Card and then as a non-U.S. taxpayer make gifts or pass their estate to...more

Do Recent FBAR Changes Indicate a Softening of the IRS’ Stance Toward Taxpayers with Foreign Financial Accounts?

Bring up the topic of FBARs (Report of Foreign Bank and Financial Accounts) with someone who has foreign financial accounts and the conversation will most likely take a nosedive. With an enforcement regime which can apply...more

A Welcome Change: Congress Finally Conforms FBAR and Tax Return Filing Deadlines

Last week Congress passed, and the President signed, a bill entitled “The Surface Transportation and Veterans Health Care Choice Improvement Act of 2015.” While this legislation was primarily directed at extending federal...more

FATCA Update: Confidentiality of Information Transmitted to IRS; Announcement of “More Favorable” IGA Terms; and More IGAs

The month of July has seen several significant developments regarding implementation of the Foreign Account Tax Compliance Act (FATCA), which has been fully effective since July 1, 2014. First, the IRS Office of Chief...more

FATCA: Making First Submissions and Maintaining Compliance

While the Foreign Account Tax Compliance Act (FATCA) became law in 2010, it has been slowly transitioning to implementation, with 2015 being the first year of required reportings. For anyone not familiar with the Act, FATCA...more

Two More Swiss Banks Reach Resolutions with U.S. Government

Today the Justice Department announced that Société Générale Private Banking (Suisse) SA (SGPB-Suisse) and Berner Kantonalbank AG (BEKB), have reached resolutions under the department’s Swiss Bank Program. With today’s...more

June 30, 2015 Filing Deadline Approaches to Report Foreign Financial Accounts

Individuals and organizations with a financial interest in or signature authority over a foreign financial account, in which the aggregate value of the accounts exceeded $10,000 at any point in 2014, may need to file FinCEN...more

Update on IRS Treatment of Civil FBAR Penalties: A Move Toward Fairness

Recently, the IRS released an internal memorandum to employees providing interim guidance on FBAR (Report of Foreign Bank and Financial Accounts) penalties. It reminds IRS examiners that when they assert FBAR penalties, the...more

2014 Foreign Financial Account Reporting Requirements

U.S. citizens or residents who owned, directly or indirectly through an entity, beneficially or who had power of attorney/signature authority over one or more foreign financial accounts with an aggregate value exceeding...more

Delinquent International Information Tax Returns May Extend the Statute of Limitations on Your Entire Federal Tax Return

More and more, U.S. taxpayers are becoming aware of their federal tax reporting obligation for foreign financial accounts, interests and assets. With increased IRS enforcement, broader media coverage of international tax...more

Foreign Account Holders: Don’t Forget to File Your FBARs by the June 30th Deadline

Now that the April 15th deadline has passed and tax season is over, most taxpayers can breathe a sigh of relief. At least for another year. For others with overseas financial accounts and interests, one more reporting hurdle...more

FBAR Filing Deadline Approaching

Reports Due by the End of June - Every U.S. person that had a financial interest in, or signature or other authority over, a foreign financial account during 2014 must electronically file with the U.S. Treasury...more

IRS Clarifies Requirements for Establishing Non-Willful Conduct in Offshore Disclosure Cases

Voluntary disclosure programs exist for taxpayers that are not in compliance with their tax and information reporting obligations with respect to foreign bank accounts and assets. The Internal Revenue Service (IRS) recently...more

FATCA – It’s Here, It’s Not Going To Be Delayed And Action May Be Needed By April 25, 2014. Is Your Fund Ready?

FATCA is the new form of 30% U.S. withholding tax that is applied to U.S. source income, such as interest and dividends paid by U.S. companies, starting as early as July 1, 2014 for payments made to non-U.S. entities that are...more

2012 Foreign Financial Account Reporting Requirements -- Important Filing Deadline on June 30, 2013

U.S. citizens or residents who owned, directly or indirectly through an entity, or who had power of attorney/signature authority over one or more foreign financial accounts with an aggregate value exceeding $10,000 at ANY...more

International Tax Planning for Businesses is Art and Politics

The recent Congressional hearings on taxation of multinational corporations drew a lot of focus on the low tax rates and low taxes paid (relative to revenue). Congress expressed outrage that the largest companies in the world...more

Eleventh Circuit Holds that Production of Foreign Bank Account Records May be Compelled in Criminal Investigation Under Required...

The Eleventh Circuit recently joined the Fifth, Seventh, and Ninth Circuits in holding that subpoenaed foreign financial records properly fall within the Required Records Exception to the Fifth Amendment privilege against...more

White Collar Watch - March 2013

In This Issue: - Eleventh Circuit Holds that Production of Foreign Bank Account Records May be Compelled in Criminal Investigation Under Required Records Exception to Fifth Amendment Privilege - Supreme Court...more

Highlights of Recently Released FATCA Regulations

On January 17, the Internal Revenue Service issued long-awaited final regulations (the Final Regulations) for implementing the Foreign Account Tax Compliance Act (FATCA) (the Final Regulations are contained in T.D. 9610). For...more

Significant Changes Made in Final FATCA Regulations

On January 17, 2013, the U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “Regulations”) implementing foreign account reporting provisions of the...more

I.R.S. Issues FATCA Final Regulations

On January 17, 2013, the IRS released final regulations for the Foreign Account Tax Compliance Act ("FATCA") to be effective on January 28, 2013. Enacted by Congress in 2010, FATCA targets non-compliant U.S. taxpayers using...more

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