US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
The Bank Secrecy Act requires certain taxpayers to submit timely FBARs to the United States reporting their interests in foreign accounts. If a taxpayer has an FBAR filing requirement and misses it, the taxpayer can be...more
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
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
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
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
An often overlooked filing obligation is the annual June 30 requirement to file the FBAR form for taxpayers with foreign bank accounts aggregating over $10,000. Late FBARs are a consistent problem and the IRS has a long...more
The IRS and the Justice Department have increased their efforts regarding criminal investigation of international tax evasion. ...more
Since the G-20 meeting on April 2, 2009, there has been a worldwide emphasis on the elimination of bank secrecy through the implementation of tax information exchange agreements ("TIEA") with countries or jurisdictions that...more