Reporting Requirements Foreign Account Tax Compliance Act

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

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

Bankers, Do your US Clients tell you everything that you need to know?

Given the information publicly revealed by “Panama Papers”, and recent IRS reminders to out-of-compliance US Taxpayers to come into full compliance with their federal tax obligations, it is critical that Bankers and Financial...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

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

¡Primera Convicción de FATCA!

El 9 de Mayo del 2016, el Departamento de Justicia (DOJ) anunció su primera convicción usando FATCA. Parece ser el principio de procesos penales por el DOJ contra violaciones aparentes o presuntas de los requisitos de...more

Upcoming FATCA Deadlines

As noted in the Foley Adviser dated April 14, 2016, there are several upcoming FATCA-related deadlines, two of which are right around the corner: ..June 30, 2016: Foreign Financial Institution Due Diligence for...more

¿Ha recibido una Carta FATCA?

Muchos Expatriados Estadounidenses están recibiendo Cartas FATCA de los bancos del extranjero alrededor del mundo. Los bancos están enviando estas cartas en anticipación al Reporte FATCA del IRS para reportar la información...more

Have You Received a FATCA Letter?

Many U.S. expatriate taxpayers are receiving “FATCA” letters from offshore banks around the world. The banks are sending the letters in anticipation of their I.R.S. FATCA reports of U.S. taxpayer offshore financial...more

Justice Department’s First FATCA Prosecution Yields Guilty Plea

On May 9, 2016, the Justice Department announced that Gregg R. Mulholland, a dual U.S. and Canadian citizen and owner of an offshore broker-dealer and investment management company based in Panama and Belize, pleaded guilty...more

Failure to Report Foreign Accounts is Illegal, IRS Warns

Maintaining a foreign bank or other financial account is not illegal. Such accounts are increasingly common, as the globe shrinks. However, in the case of U.S. citizens or residents (and certain non-residents), failing to...more

Annual Estate Planning Newsletter: Part Five

Action Item: This is the fifth installment of our Annual Estate Planning Newsletter, and focuses on foreign matters. We urge you to review this installment to ensure that your 2016 estate and tax planning is in...more

FATCA Update: Treasury Issues Long-Awaited Rules For Foreign Asset Reporting by Domestic Entities

The Treasury Department has finally issued regulations implementing the rules requiring domestic entities to annually disclose their foreign financial assets to the Internal Revenue Service. In 2010, as part of the enactment...more

FY2017 Budget Proposal Sets Its Sights on Insurance Companies

On February 9, the Obama Administration released its fiscal year 2017 budget proposal (FY2017 Budget). Many of the tax proposals included in the FY2017 Budget closely follow those included in the President’s fiscal year 2016...more

2015 Year-End Tax Planning for Businesses

As 2015 draws to a close, there is still time to reduce your 2015 taxes and plan ahead for 2016. This advisory highlights several potential tax-saving opportunities for business owners to consider. ...more

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

2015-16 Compliance Developments & Calendar for Private Fund Advisers

Registered investment advisers (RIAs) are required to review their policies and procedures on at least an annual basis. As an aid to the required review and to assist with timely completion of required compliance tasks, below...more

Financial Services Quarterly Report - Third Quarter 2015: Developments in the Luxembourg Financial Sector

The Luxembourg government has brought to Parliament a bill of law transposing UCITS V into Luxembourg’s UCI Law and AIFM Law. Further, the Luxembourg CSSF published a new version of its AIFMD Frequently Asked Questions, among...more

FATCA: IRS Extends Transitional Rules

On September 18, 2015, the IRS announced its intention to amend the U.S. FATCA regulations to extend the effectiveness of certain transitional rules, including...more

FATCA Update: Institute of International Bankers Submits Comment Letter on FATCA Regulations

The Institute of International Bankers (IIB) has submitted a comment letter (available through Bloomberg BNA here; subscription required) to the Internal Revenue Service addressing various issues arising under the FATCA...more

Investment Funds Update - Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

Enforcement – FCA Fines £13.2 Million for Transaction Reporting Failures - The FCA fined Merrill Lynch International (MLI) £13.2 million on 22 April 2015 for incorrectly reporting 35,034,810 transactions and failing to...more

BVI FATCA Compliance Deadlines Extended

This week the British Virgin Islands (BVI) announced the extension of its FATCA registration and reporting deadlines, as follows...more

Top 10 Foreign Bank Account Reporting (FBAR) Mistakes (And How to Fix Them)

While FBAR reporting rules are frequently misunderstood, US persons have several options to correct mistakes, before the government learns of the non-compliance. June 30th is the annual deadline for filing a Foreign...more

IRS Plans to Shift Risk of Withholding Agent Fraud to the Taxpayer for Foreign Withholding

Chapter 3 of the Internal Revenue Code requires payors (and recipients) of certain types of U.S. source income to withhold tax if the beneficial owner or recipient is a non-U.S. person for income tax purposes. Chapter 4 also...more

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