News & Analysis as of

Foreign Bank Accounts

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

Automatic exchange of information and insurance companies - a question of compliance

by Hogan Lovells on

Automatic exchange of information (AEOI) regimes, primarily aimed at curbing tax avoidance through the use of foreign accounts and investment platforms, have recently become a global trend, starting with the adoption of the...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

Reminder: FBARs Due in April Starting This Year

by Charles (Chuck) Rubin on

Until now, the Reports of Foreign Bank and Financial Accounts (FBAR) for foreign financial accounts was due on June 30 of each year, for purposes of reporting accounts for the preceding calendar year....more

Why are Americans Working Abroad Giving Up Citizenship?

by Ronald Shapiro on

Many Americans working abroad are renouncing their citizenship because of tax requirements imposed by U.S. tax laws. For Illinois residents employed overseas, an immigration lawyer in Chicago can explain tax laws that have an...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

New York’s high court finds jurisdiction over foreign bank on basis of correspondent bank account activity

by DLA Piper on

In a ruling that three dissenting judges warned would “have grave implications for correspondent banking relationships,” New York’s Court of Appeals has reinstated claims against a Swiss bank after concluding that its alleged...more

¿Sabe usted el propósito de los Procedimientos de Presentación de Cumplimiento Racionalizados?

by Foodman CPAs & Advisors on

Procedimientos Racionalizados de Presentación de Cumplimiento (Streamlined Filing Compliance Procedures) es una de las opciones disponibles para los contribuyentes Estadounidenses con activos e ingresos financieros...more

138 Results
|
View per page
Page: of 6
Cybersecurity

"My best business intelligence,
in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.