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International Tax Issues Foreign Bank Account Report

Allen Barron, Inc.

US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen

Allen Barron, Inc. on

In US Expatriate Tax Planning – Part 2, Ms. Allen picks up the conversation regarding tax and legal issue U.S. expatriates might face. The discussion turns to real estate matters, and the issue of moving money from the United...more

Allen Barron, Inc.

Are you Thinking of Moving to Another Country - A Few Things to Consider

Allen Barron, Inc. on

Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more

Allen Barron, Inc.

US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen

Allen Barron, Inc. on

In the US Expatriate Tax Planning podcast, Janathan Allen discusses important tax issues from the perspective of a US Expatriate. One of the first and most important thing to know for any US taxpayer is the United States...more

Allen Barron, Inc.

Part 2 – International Tax Primer for US Taxpayers and Expatriates

Allen Barron, Inc. on

We continue with Part 2 – International Tax Primer for US Taxpayers and Expatriates with one of the most common forms associated with foreign asset and income reporting to the IRS: Form 8938, the Statement of Specified...more

Allen Barron, Inc.

An International Tax Primer for US Taxpayers and Expatriates – Part 1 of 2

Allen Barron, Inc. on

Welcome to part 1 of our Allen Barron International Tax Primer for US Taxpayers and Expatriates. The United States is one of the few countries in the world that taxes its citizens on their worldwide income. US taxpayers are...more

Freeman Law

Unreported Foreign Accounts? How to Choose the "Right" International Tax Attorney to Help You

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If you have unreported foreign accounts, you are not alone.  Every year, I speak with hundreds of clients with tax non-reporting issues (e.g., FBARs, Form 8938, Form 3520, Form 3520-A, etc.).  The good news:  the IRS offers...more

Freeman Law

Reviewing a Foreign Legal Structure

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Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure - U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and...more

Freeman Law

IRS Issues FBAR Reference Guide

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The IRS and FBARs - On March 30, 2022, the IRS issued Publication 5569, Report of Foreign Bank & Financial Accounts (FBAR) Reference Guide. The 12-page publication provides helpful information to both taxpayers and tax...more

Freeman Law

The Evolving Standard of “Willfulness” in FBAR Cases: Where are We Now?

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The concept of “willfulness” is an important one in the FBAR civil penalty context. Indeed, a taxpayer’s willful failure to file a timely and accurate FBAR may result in significant penalties: the higher of 50-percent of...more

Freeman Law

Challenging FBAR Penalties in Federal Court: FBAR Litigation

Freeman Law on

In most cases, IRS exam initiates FBAR assessments. And, after an IRS examiner determines that an FBAR penalty is appropriate, taxpayers are generally afforded pre- or post-assessment appeals rights with the IRS Independent...more

Freeman Law

Is My Foreign Retirement Account Subject to IRS Information Return Reporting (FBAR, 3520, etc.)?

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United States citizens and residents[i] are subject to federal income tax on their worldwide income. For example, even if a United States citizen permanently relocates to a foreign country, he or she will generally continue...more

Miller Nash LLP

Today in Tax: Foreign Account Reporting Requirements and Divisive Tax-Free Reorganizations

Miller Nash LLP on

FBAR Noncompliance Leads to More Severe Penalties in the 5th Circuit Penalties for FBAR violations can be severe if applied on a per-account basis, as opposed to a per-form basis. However, a taxpayer with “reasonable cause”...more

Freeman Law

Why Taxpayers in Louisiana, Texas, and Mississippi Should Consider the IRS’s Streamlined Compliance Procedure Program Now

Freeman Law on

On November 30, 2021, the United States Court of Appeals for the Fifth Circuit issued its opinion in U.S. v. Bittner. Contrary to decisions of other federal courts, the Fifth Circuit concluded that it was proper for the IRS...more

Gray Reed

Non-Willful FBAR Penalties Will be Much Higher in the Fifth Circuit

Gray Reed on

On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account...more

Freeman Law

A Summary of the IRS’ Streamlined Filing Compliance Procedures

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The IRS’ streamlined filing procedures were first offered by the IRS on September 1, 2012. Since that time, the IRS has made several revisions. A current summary of the IRS’ Streamlined Filing Compliance Procedures is...more

Freeman Law

The FBAR (Report of Foreign Bank and Financial Accounts): Everything You Need to Know

Freeman Law on

What is the Report of Foreign Bank and Financial Accounts (FBAR)? Congress enacted the statutory basis for the requirement to report foreign bank and financial accounts in 1970 as part of the “Currency and Foreign...more

Carlton Fields

Les Obligations Fiscales et Formulaires Fiscaux aux États-Unis

Carlton Fields on

Qu’est-ce que le Foreign Account Tax Compliance Act (« FATCA ») ? Depuis plusieurs années, l’IRS mène une campagne agressive contre la fraude fiscale internationale et la nondéclaration de comptes bancaires et autres...more

Proskauer - Tax Talks

Extension of FBAR Filing Deadline for Certain Filers

Proskauer - Tax Talks on

On December 9, 2020, the Financial Crimes Enforcement Network (“FinCEN”) issued Notice 2020-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain...more

Freeman Law

Death Doesn’t Stop the IRS—Failure to File FBARs

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Benjamin Franklin once famously wrote in a 1789 letter, “In this world nothing can be said to be certain, except death and taxes.” Many recognize the truth in Mr. Franklin’s statement. Some may also believe that certain death...more

Freeman Law

International Tax Treaty: Mexico

Freeman Law on

The world’s most populous Spanish-speaking nation. Mexico is a Federation comprised of 32 states, being Mexico City the capital of the country. The government of Mexico is divided in three branches: the Legislative Branch in...more

Freeman Law

Everything That You Need To Know About International Tax Penalties

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International information return penalties are civil penalties assessed by the IRS against a United States person for failing to timely file complete and accurate international information returns required by specific...more

Proskauer - Tax Talks

Extension of FBAR Filing Deadline for Certain Filers

Proskauer - Tax Talks on

On December 20, 2019, the Financial Crimes Enforcement Network (“FinCEN”) issued Notice 2019-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain...more

Foodman CPAs & Advisors

IRS Criminal Investigation Unit (IRS-CI) will find you!

Due to the Foreign Account Tax Compliance Act (FATCA) and the work of IRS special agents, international tax transparency is here. There is virtually nowhere to hide. On 1/18/17, the Department of Justice (DOJ) reported that...more

Blank Rome LLP

IRS Commissioner Hints That OVDP Modifications Are in the Works

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Since 2009, the Internal Revenue Service has offered three different amnesty programs for taxpayers with undeclared foreign bank accounts. These programs, the current version of which is entitled the Offshore Voluntary...more

Holland & Knight LLP

IRS Unveils New Compliance Program

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According to the Miriam Webster dictionary, credibility is defined as "the quality or power of inspiring belief." When IRS Commissioner John Koskinen took office, one of his many roles involved trying to restore the integrity...more

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