News & Analysis as of

Foreign Bank Account Report

Undisclosed Foreign Accounts, Part II

by Moskowitz LLP on

The executor of a decedent’s estate has a duty to act in a prudent manner and in accordance with the law. At times, this may result in having to take an unpopular position or action that angers the beneficiaries....more

Undisclosed Foreign Accounts

by Moskowitz LLP on

Serving as Executor can at times be more of a headache than an honor. On top of a pile of paperwork and dealing with a multitude of family issues, you can be sued!...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

Manafort Indictment Alleges High-End International Money Laundering and Tax Fraud Involving Offshore Accounts

by Ballard Spahr LLP on

As the world now knows, an indictment against Paul Manafort, Jr., a former campaign chairperson for now-President Donald Trump, and Manafort’s associate, Richard Gates III, was unsealed yesterday. ...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

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

Are you a Taxpayer identified by IRS for not Reporting Offshore Financial Assets?

by Foodman CPAs & Advisors on

Taxpayers with unreported foreign financial assets and income run the risk of having the Government determine if their conduct was willful or non-willful. The definition of “Willful" or "non-willful” in Taxpayer’s conduct...more

No Rest For The Weary: Offshore Tax Evasion Crackdown Continues With Flurry Of Mid-Summer Activity

by Fox Rothschild LLP on

Dashing any thought that they were taking a hiatus from investigating and prosecuting taxpayers with secret offshore bank accounts and the bankers that helped them, the Justice Department and Internal Revenue Service have...more

FBAR Penalties Now Adjusted for Inflation: Abatement/Mitigation Still Possible

If you haven’t filed your Report of Foreign Bank and Financial Accounts (FBARs) on a timely basis, you could be at risk of a higher civil penalty assessment. Inflation-adjusted FBAR penalties are now in effect....more

FBAR Penalty Amounts are in the “Best Judgement” of an IRS Examiner

by Foodman CPAs & Advisors on

The Report of Foreign Bank and Financial Accounts (FBAR) is not a tax form. Its filing is not required by the Internal Revenue Code. It is required by Title 31 of the Code of Federal Regulations. Title 31 is the Bank Secrecy...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

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

Applying Overpayments of Tax to Tax and the Offshore Penalty in the OVDP Program

by Charles (Chuck) Rubin on

The OVDP program allows taxpayers to remedy deficient disclosure filings relating to offshore accounts for a fixed penalty amount. As part of the program, taxpayers must file either original or amended tax returns which...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

Government Refuses to Define "willfulness" for FBAR Purposes

by Sanford Millar on

Whether a taxpayer's conduct in failing to report foreign financial accounts is "willful" or "non-willful" makes a huge difference in penalty determination. However the government refuses to publish a definition of...more

Two Important New International Tax Filings

by Charles (Chuck) Rubin on

While not the only international reporting changes that are occurring, there are two significant ones that apply for the current filing season for 2016 returns. First is the FBAR, which reports interests in foreign...more

Choose Opt Out Option Wisely in Offshore Voluntary Disclosure Program

Since 2009, the Internal Revenue Service has offered a variety of offshore voluntary disclosure programs (collectively, OVDP) under which a U.S. taxpayer can disclose previously undisclosed offshore activities. However, these...more

IRS Agent Discusses the Look-Back Period for Filing Delinquent International Information Returns

We represent a client who may need to file delinquent international information returns under the IRS Delinquent International Information Return Submission Procedures. These procedures invite taxpayers who meet the...more

Procedural Oversight by IRS Turns Out to Be a Good Weapon for Taxpayers

Good news for taxpayers: a procedural requirement on the IRS’s part that historically had not been strictly enforced has recently risen above the surface. Taxpayers under audit, in particular those litigating in Tax Court,...more

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