News & Analysis as of

Foreign Bank Accounts

Wire Transfer Audits and FATCA: What Every Taxpayer Needs to Know

FATCA: The Foreign Account Tax Compliance Act was signed into law by President Obama on March 18, 2010. There are two purposes for FATCA....more

FinCEN Clarifies Upcoming FBAR Due Date For Calendar Year 2017

by Fox Rothschild LLP on

Today the Treasury Department’s Financial Crimes Enforcement Network posted a “FBAR Due Date Clarification” on its website, which confirms that the annual filing deadline for FinCEN Form 114 (commonly referred to as the FBAR...more

A Day Of Reckoning For Recalcitrant Taxpayers?

by Carlton Fields on

Following disclosures by UBS whistleblower Bradley Birkenfeld, the IRS launched an aggressive enforcement campaign against undeclared offshore income and financial accounts in 2009. Over time, it has offered a series of...more

¿Será la pregunta para el año 2017: ¿tiene cuentas financieras extranjeras?

by Foodman CPAs & Advisors on

Desde la crisis financiera mundial que comenzó en el 2007, los contribuyentes Estadounidenses e Internacionales han estado bajo un escrutinio creciente. El sistema financiero ha sido fuertemente regulado y monitoreado de...more

Will the question for the Year 2017 be: Do you have Foreign Financial Accounts?

by Foodman CPAs & Advisors on

Since the Global Financial Crisis that began in 2007, domestic and international Taxpayers have been under increasing scrutiny. The financial system has been heavily regulated and closely monitored. In addition, the US Tax...more

FBAR Filing Deadline Further Extended

by Morgan Lewis on

Certain individuals who have only signature authority over foreign financial accounts now have until April 15, 2019 to file the Report of Foreign Bank and Financial Accounts....more

US prosecutors seek tenfold increase in offshore evasion sentences

by Sanford Millar on

A conviction for failure to report offshore financial account now carries a far greater risk of a lengthy prison term according to Mark Daly, senior litigation counsel at the U.S. Department of Justice. US prosecutors seek...more

DOJ Announces Major New Shift in Criminal Sentencing in Offshore Tax Matters

At the 34th Annual National Institute on Criminal Tax Fraud in Las Vegas yesterday afternoon, Mark Daly, DOJ Tax Division Senior Litigation Counsel announced a major new shift in how the Department of Justice plans to argue...more

On Eve Of “Paradise Papers” Release, At-Risk Individuals Should Consider Immediate Action To Mitigate Potential For Criminal...

by Fox Rothschild LLP on

Tomorrow morning (November 17) the International Consortium of Investigative Journalists (ICIJ) is set to release publicly the first set of comprehensive data from the recent “Paradise Papers” leak. The initial data will...more

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

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

Justice Department’s Latest Offshore Bank Resolution Confirms Value Of Self-Disclosure And Voluntary Remediation By At-Risk...

by Fox Rothschild LLP on

The Justice Department revealed its latest offshore bank resolution by announcing that it had entered into a non-prosecution agreement with a Swiss asset management firm called Prime Partners. This means that Prime Partners...more

Cumplimiento Fiscal Internacional

by Foodman CPAs & Advisors on

Detectar, disuadir y responder al incumplimiento internacional son desafíos clave que enfrentan las autoridades tributarias de todo el mundo. El incumplimiento fiscal internacional es un problema significativo reconocido por...more

Overview of IRS Penalties for Individuals with Foreign Bank Accounts and Investments

by Blank Rome LLP on

Earlier this spring, the Internal Revenue Service ("IRS") Large Business and International Division identified several "campaigns" or areas where it plans to focus its audit resources. One campaign involved taxpayers who...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

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

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

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

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

Stay out of TROUBLE: Make sure your CPA is asking you the right QUESTIONS regarding Foreign Accounts!

by Foodman CPAs & Advisors on

US International tax is complicated. It often overwhelms US Taxpayers. That is why an international tax specialist CPA is the best choice for the work. Nonetheless, many Taxpayers seek the help of tax return preparers...more

NBU cancels certain individual licenses for individuals-residents of Ukraine

by Dentons on

On 23 February 2017 the National Bank of Ukraine (NBU) amended its regulations whereby it revisited the legal regime for placement money on foreign accounts and making foreign investments by individuals-residents of Ukraine....more

New Filing Date for Foreign Bank Account Return

If you have a foreign bank account (or signatory authority on a foreign bank account), you are required to file a Form 114 (commonly called an FBAR) if at any point during the calendar year the combined balance in all of your...more

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