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Foreign Account Tax Compliance Act Foreign Bank Account Report

The Foreign Account Tax Compliance Act is a United States federal statute enacted in 2010 as part of the Hiring Incentives to Restore Employment Act (HIRE Act). FATCA aims to improve compliance of U.S. taxpayers... more +
The Foreign Account Tax Compliance Act is a United States federal statute enacted in 2010 as part of the Hiring Incentives to Restore Employment Act (HIRE Act). FATCA aims to improve compliance of U.S. taxpayers by capturing tax revenue related to foreign assets and off-shore accounts.  less -

Income, from Whatever Exchange, Mine, or Fork Derived: The Basics of U.S. Cryptocurrency Taxation

by Proskauer - Tax Talks on

In this first of (we hope) many posts on the interesting and myriad tax issues arising in the world of cryptocurrency and blockchain technology, we focus on the very basic U.S. federal income tax consequences of...more

The Manafort Indictment and what it means to you.

by Sanford Millar on

On October 30, 2017 Paul Manafort, the former campaign chair for president Donald Trump was indicted by a Federal Grand Jury in the District of Columbia. The charges arise from Manafort's unregistered consulting and...more

Could U.S. Tax Reform Include An End To Citizenship-Based Taxation?

by Fox Rothschild LLP on

With tax reform a hot topic in Washington, key Republican lawmakers in Congress are considering a major change to the U.S. tax system: eliminating citizenship-based taxation and moving to a residence-based system, according...more

2017 OVDP Declines and Withdrawals Campaign: Certain U.S. Taxpayers at Risk of Audit

In 2016, the Treasury Inspector General for Tax Administration (TIGTA) released a report which assessed how well that IRS was managing the Offshore Voluntary Disclosure Program (OVDP). OVDP is one of the programs taxpayers...more

New Due Date for “FBAR” Filings - Report of Foreign Bank and Financial Accounts now due on Tax Day, with auto-extension for six...

Federal law requires U.S. citizens and resident aliens to report world-wide income, including income from foreign trusts, bank and securities accounts. In addition to attaching Schedule B to their tax returns disclosing...more

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

by Foodman CPAs & Advisors on

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

Important Dates and Reminders for Investment Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and Commodity Pool...

by Foley Hoag LLP on

Investment Advisers - Annual Compliance Reviews - All investment advisers registered with the Securities and Exchange Commission (“SEC”) or The Commonwealth of Massachusetts are required to review their compliance...more

New Extended Due Dates for Foreign Bank Account Reports (FBAR)

by McNair Law Firm, P.A. on

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

Enforcement of Foreign Tax Claims

by Sanford Millar on

In many cases we have handled the taxpayers were dual nationals who have not only failed to adequately disclose and report foreign bank account and income to the IRS, but have also failed to report to the other country. This...more

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

by Foodman CPAs & Advisors on

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

The High Cost of Being Noncompliant with the Internal Revenue Code

by Holland & Knight LLP on

The IRS currently offers the following five programs for noncompliant taxpayers: (i) the Offshore Voluntary Disclosure Program (OVDP), (ii) Streamlined Domestic Offshore Procedures, (iii) Streamlined Foreign Offshore...more

Tax Evasion - Nowhere Left to Hide

by K&L Gates LLP on

Global tax evasion remains a major problem for governments around the world. At a time when virtually all of the governments from the world’s major economies seek additional revenue, the attractiveness to taxpayers of...more

Sonhos Interrompidos - Como uma não conformidade tributária pode destruir o Sonho Americano de imigrantes não registrados - Parte...

by Gerald Nowotny on

Panorama - A Parte I desta série teve enfoque no pesadelo e problema imprevisto de declarações de impostos não apresentadas para imigrantes não registrados. As consequências de "empurrar o problema com a barriga"...more

Broken Dreams - How Tax Non-Compliance Can Destroy the American Dream of Undocumented Immigrants - Part 2

by Gerald Nowotny on

Part I of this series focused on the unforeseen nightmare and problem of unfiled tax returns for undocumented immigrants. The consequences of “kicking the can down the road”, will have significant legal and financial...more

IRS and DOJ are Reviewing and Scrubbing Offshore Accounts Data to Build Civil and Criminal Cases

During the June 24, 2016 Tax Controversy Conference held at New York University, officials from both the Department of Justice (DOJ) and the Internal Revenue Service (IRS) emphasized their focus on analyzing the avalanche of...more

Don’t Let The I.R.S. Define Your Conduct As Willful, or Else………

by Foodman CPAs & Advisors on

Something that most of us don’t realize is that Internal Revenue Service has stated that the taxpayer is responsible to learn IRS requirements within the historic U.S. framework of a voluntary reporting system. The IRS...more

Foreign Bank Account Reports Due June 30

by Sanford Millar on

U.S. Taxpayers who directly or indirectly controlled foreign financial accounts in 2015 are reminded that the deadline to file a Report of Foreign Financial Account (FBAR) FinCEN Form 114 is June 30. Taxpayers with unfiled...more

Private Eyes They’re Watching You – Offshore Planning after the Panama Papers

by Gerald Nowotny on

Overview - If you have been reading my articles on JD Supra for a while, you will know that I love Afro-Cuban and Brazilian music. Nevertheless, the Hall and Oates song Private Eyes, is a more fitting song to describe...more

Failure to Report Foreign Accounts is Illegal, IRS Warns

by Ballard Spahr LLP on

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

by Blank Rome LLP on

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

[Event] Tax Advantaged Strategies for Foreign Source Income and Investments: Required Tax and IRS Reporting - Oct. 28th,...

by Moskowitz LLP on

Join us at Coconut Bay Thai Restaurant & Bar and learn about tax strategies geared towards individuals. Light appetizers and good company will be provided! Topics include: Foreign Investment in US Real Estate ...more

Offshore Accounts Still Focus of IRS Enforcement

by Sanford Millar on

The following Notice from the IRS reiterates the enforcement focus on offshore accounts. Anyone with an unreported offshore account needs to consult counsel and discuss, their compliance options under the "attorney-client...more

New Regulations on F Reorganizations

by Alston & Bird on

In late September, the IRS issued final regulations describing six requirements for a transaction or series of transactions to qualify as a reorganization under Section 368(a)(1)(F) (an “F reorganization”). The IRS...more

When the Fifth Amendment Privilege Doesn't Work-Tax Cases

by Sanford Millar on

A recent decision of the Third Circuit Court of Appeals illustrates the futility of expecting that the Fifth Amendment Privilege Against Self-incrimination will shield taxpayers from production of offshore financial records. ...more

Lawsuit by U.S. Presidential Candidate Challenges the Constitutionality of FATCA

by Hodgson Russ LLP on

Senator Rand Paul, R-Ky., along with six current and former U.S. citizens living abroad, filed a lawsuit, July 14, in the U.S. District Court for the Southern District of Ohio challenging the constitutionality of the Foreign...more

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