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Foreign Bank Accounts Foreign Bank Account Report International Tax Issues

Allen Barron, Inc.

US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen

Allen Barron, Inc. on

In US Expatriate Tax Planning – Part 2, Ms. Allen picks up the conversation regarding tax and legal issue U.S. expatriates might face. The discussion turns to real estate matters, and the issue of moving money from the United...more

Freeman Law

Unreported Foreign Accounts? How to Choose the "Right" International Tax Attorney to Help You

Freeman Law on

If you have unreported foreign accounts, you are not alone.  Every year, I speak with hundreds of clients with tax non-reporting issues (e.g., FBARs, Form 8938, Form 3520, Form 3520-A, etc.).  The good news:  the IRS offers...more

Freeman Law

IRS Issues FBAR Reference Guide

Freeman Law on

The IRS and FBARs - On March 30, 2022, the IRS issued Publication 5569, Report of Foreign Bank & Financial Accounts (FBAR) Reference Guide. The 12-page publication provides helpful information to both taxpayers and tax...more

Freeman Law

The Evolving Standard of “Willfulness” in FBAR Cases: Where are We Now?

Freeman Law on

The concept of “willfulness” is an important one in the FBAR civil penalty context. Indeed, a taxpayer’s willful failure to file a timely and accurate FBAR may result in significant penalties: the higher of 50-percent of...more

Freeman Law

Why Taxpayers in Louisiana, Texas, and Mississippi Should Consider the IRS’s Streamlined Compliance Procedure Program Now

Freeman Law on

On November 30, 2021, the United States Court of Appeals for the Fifth Circuit issued its opinion in U.S. v. Bittner. Contrary to decisions of other federal courts, the Fifth Circuit concluded that it was proper for the IRS...more

Gray Reed

Non-Willful FBAR Penalties Will be Much Higher in the Fifth Circuit

Gray Reed on

On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account...more

Freeman Law

A Summary of the IRS’ Streamlined Filing Compliance Procedures

Freeman Law on

The IRS’ streamlined filing procedures were first offered by the IRS on September 1, 2012. Since that time, the IRS has made several revisions. A current summary of the IRS’ Streamlined Filing Compliance Procedures is...more

Freeman Law

The FBAR (Report of Foreign Bank and Financial Accounts): Everything You Need to Know

Freeman Law on

What is the Report of Foreign Bank and Financial Accounts (FBAR)? Congress enacted the statutory basis for the requirement to report foreign bank and financial accounts in 1970 as part of the “Currency and Foreign...more

Proskauer - Tax Talks

Extension of FBAR Filing Deadline for Certain Filers

Proskauer - Tax Talks on

On December 9, 2020, the Financial Crimes Enforcement Network (“FinCEN”) issued Notice 2020-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain...more

Freeman Law

Death Doesn’t Stop the IRS—Failure to File FBARs

Freeman Law on

Benjamin Franklin once famously wrote in a 1789 letter, “In this world nothing can be said to be certain, except death and taxes.” Many recognize the truth in Mr. Franklin’s statement. Some may also believe that certain death...more

Proskauer - Tax Talks

Extension of FBAR Filing Deadline for Certain Filers

Proskauer - Tax Talks on

On December 20, 2019, the Financial Crimes Enforcement Network (“FinCEN”) issued Notice 2019-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain...more

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