News & Analysis as of

Foreign Bank Account Report FinCEN

FinCEN Provides FBAR Relief To Victims Of The California Wildfires

by Fox Rothschild LLP on

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced today that California wildfire victims in affected areas of California have until January 31, 2018, to file their Report of Foreign Bank and...more

FinCEN Provides Updated FBAR-Filing Relief To Victims of Hurricanes Harvey, Irma, And Maria

by Fox Rothschild LLP on

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) today updated two previous notices regarding FBAR-filing relief to victims of the recent hurricanes. Extension filers have until January 31, 2018 to...more

Court Revisits FBAR Willfulness Requirement and Concludes Taxpayer Is Not Willful

In a recent decision, the United States District Court for the Eastern District of Pennsylvania reexamined the requirements for willful failure to file a TD F 90-22.1, the predecessor to the current FinCEN Form 114, Report of...more

FinCEN Extends FBAR Relief To Victims Of Hurricane Irma

by Fox Rothschild LLP on

We previously reported that the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) had granted FBAR filing relief to the victims of Hurricane Harvey. FinCEN announced today that Hurricane Irma victims in...more

FinCEN Provides FBAR Relief To Victims Of Hurricane Harvey

by Fox Rothschild LLP on

The Financial Crimes Enforcement Network (FinCEN) announced today that Hurricane Harvey victims in the affected areas of Texas have until January 31, 2018 to file their 2016 FBARs (that would have otherwise been due on...more

IRS Reminds U.S. Taxpayers Living Abroad of Misc. Filing Due Dates and Filings

by Charles (Chuck) Rubin on

In News Release 2017-105, the IRS reminded U.S. taxpayers living abroad: The extended due date, if the taxpayer had his or her tax home and abode abroad on the original due date, is June 15. But interest on taxes runs from...more

Developing a Strategy to Fight FBAR Penalties

by Carlton Fields on

Since 2009, the number of FBAR penalties imposed for failures to report foreign bank accounts and the size of the penalties have both increased dramatically. Originally published in The Tax Advisor....more

IRS Targets Globally-Mobile Individuals and Businesses: The Importance of Proactive Planning

IRS targets globally-mobile individuals and businesses through its Global High Wealth Industry Group and its Large Business and International Division. Targeted taxpayers find these audits distracting, taking time from...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

For High-Income and International Taxpayers: Defensive Tax Planning

The Importance of Defensive Tax Planning - IRS audit criteria target high-income taxpayers, especially those with reported foreign income or foreign financial assets. Targeted high income taxpayers include...more

Reporting A Closely Held U.S. Corporation’s Overseas Activities

by Farrell Fritz, P.C. on

We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...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

FBAR Filing Deadline Extended for Certain Filers

by Proskauer Rose LLP on

On December 16, 2016, FinCEN issued Notice 2016-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain individuals with signature or other authority over...more

Filing Deadline Extended for Certain FBAR Filers

by Morgan Lewis on

Certain individuals who have only signature authority over foreign financial accounts now have until April 15, 2018 to file the Report of Foreign Bank and Financial Accounts....more

De-Risking 101

by Foodman CPAs & Advisors on

Bank Secrecy Act of 1970 - Requires U.S. financial institutions to assist U.S. government agencies to detect and prevent money laundering by keeping records of cash purchases of negotiable instruments, and file reports...more

9th Circuit: Online Poker Accounts Not Reportable on FBAR

by Blank Rome LLP on

On July 21, 2016, the Ninth Circuit in United States v. Hom, No. 14-16214 D.C. No. 3:13-cv-03721-WHA (9th Cir. 2016), determined that a taxpayer who held an online poker account with PokerStars and PartyPoker was not required...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

FinCEN Extends Filing Deadline for Certain FBAR Filers

by Morgan Lewis on

Certain individuals who have only signature authority over foreign financial accounts now have until April 15, 2017 to file the Report of Foreign Bank and Financial Accounts....more

Deadline: Foreign Bank Account Reports Due June 30, 2016

Any U.S. person who has a financial interest in or signature authority over one or more foreign financial accounts with an aggregate value over $10,000 (on any day of the year) must report the accounts to the Treasury...more

FBAR: 2015 Reports Due by June 30, 2016

by Foley Hoag LLP on

Every U.S. person (including both individuals and entities, as discussed below) that had a financial interest in, or signature or other authority over, one or more foreign financial accounts during 2015 must electronically...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

FinCEN Proposes Revised FBAR Rules

by Locke Lord LLP on

On March 1, 2016, the Financial Crimes Enforcement Network (FinCEN) proposed rules that would revise and clarify certain provisions regarding the filing of Reports of Foreign Bank and Financial Accounts (FBAR). The rules, if...more

Proposed FBAR Regulations Expand Filing Exemption and Reporting Requirements

by Proskauer Rose LLP on

As reported in our prior client alerts, the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), must be filed by a U.S. person that holds a financial interest in, or signature or other authority over, a...more

Financial Services Weekly News - March 2016

by Goodwin on

Regulatory Developments - CFPB Now Accepting Complaints on Online Marketplace Lenders - On March 7, the Consumer Financial Protection Bureau (CFPB) announced two initiatives: it will now accept complaints from...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

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