News & Analysis as of

Foreign Bank Accounts Tax Planning

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

What 2022 Has Taught Us About FBAR Willfulness

Freeman Law on

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

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

Foodman CPAs & Advisors

Cómo las administraciones tributarias pueden monitorear la capacitación en cumplimiento de FATCA y CRS de las IF

Un nuevo informe de la Organización para la Cooperación y el Desarrollo Económico (OCDE) dice que las administraciones tributarias pueden evaluar el cumplimiento de FATCA y CRS de las instituciones financieras al monitorear...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

Criminal Tax Statutes of Limitations and Suspensions: 18 U.S.C. § 3292 and the Fifth Circuit’s Decision in Pursley

Freeman Law on

In civil and in criminal cases, the Government must generally act within a certain prescribed time to take action against taxpayers. In legal parlance, this period of time is known as the “statute of limitations.” The...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

FBAR Penalties: Another Court Holds that FBAR Penalties Can Exceed the Regulatory Ceiling

Freeman Law on

The Report of Foreign Bank and Financial Accounts (i.e., the “FBAR”) was for many years confined to the lonely backwaters of Title 31 of the United States Code—the intriguingly-named Bank Secrecy Act. For years, compliance...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

Foodman CPAs & Advisors

Closing A Foreign Bank Account Will Not Solve A Taxpayer’s Disclosure Problem

IRS is interested in U.S. Taxpayer financial accounts everywhere in the world.  If the IRS learns that a Taxpayer has undisclosed reportable accounts or income before a US Taxpayer reports them, the Taxpayer can face serious...more

Foodman CPAs & Advisors

19 Possible Questions That Your Tax Preparer Ought to Ask Regarding Foreign Accounts and Assets

Many Taxpayers with international entanglements seek the assistance of tax return preparers without U.S. international tax reporting experience.  Because US International tax reporting is complicated and often overwhelming...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

Foodman CPAs & Advisors

Willfulness and IRS Foreign Account Reporting Requirements

The IRS Mission Statement states that: “the taxpayer’s role is to understand and meet his or her tax obligations”.   Taxpayers fill out their own returns under a “self-assessment voluntary reporting system” because the...more

Foodman CPAs & Advisors

FBAR Penalties: Is it per Account or per Violation?

U.S. Taxpayers (includes a citizen, permanent resident, corporation, partnership, limited liability company, trust and estate) are required to file a Report of Foreign Bank and Financial Accounts (FBAR) if they have...more

Adler Pollock & Sheehan P.C.

Insight on Estate Planning - June/July 2019: Do you know when an FBAR must be filed?

If one has a financial interest in, or signature authority over, foreign financial accounts with an aggregate value exceeding $10,000 at any time during the calendar year, he or she must file FinCEN Form 114, “Report of...more

Foodman CPAs & Advisors

Is it time for Foreign Financial Institutions to hire IRS Representation?

The Responsible Officer (RO) of a Participating Foreign Financial Institution (PFFI) or Reporting Model 2 FFI is required to file the FFI’s FATCA certification of an Entity’s preexisting accounts (COPA) and its Periodic...more

Foodman CPAs & Advisors

IRS gives Internal Revenue Manual Voluntary Disclosure Consideration if…….

Foodman CPAs & Advisors on

When IRS reviews a criminal tax case, consideration is given to various factors such as whether a voluntary disclosure was made, whether prosecution exists, the health, age and mental condition of the Taxpayer and whether a...more

Foodman CPAs & Advisors

Certificaciones FATCA Son Debidas El 15 De Diciembre Y Es Mejor Certificar

Una certificación FATCA consiste en respuestas a una o más serie de preguntas que los Oficiales Responsables (RO) de ciertas entidades deben responder y enviar al IRS para confirmar el cumplimiento de las entidades con los...more

Foodman CPAs & Advisors

FATCA certifications due December 15 and it is best to certify

A FATCA certification consists of answers to one or more series of questions that the Responsible Officers (RO) of certain entities must answer and submit to the IRS to confirm the entities’ compliance with the requirements...more

Foodman CPAs & Advisors

Avoid this while filing your taxes

To avoid possible scrutiny or oversight by the IRS, Accuracy is a key factor when filing Tax Returns. Taxpayers want to make sure that their returns are processed correctly by the IRS. ...more

Foodman CPAs & Advisors

FBARs 101

US Taxpayers (which includes US Citizens, Permanent Residents, Trusts, Estates, and Domestic Entities) with an interest in foreign financial accounts that meet the reporting threshold of an aggregate value exceeding $10,000...more

Blank Rome LLP

Annual Estate Planning Newsletter: Part Five

Blank Rome LLP on

Action Item: This is the fifth installment of our Annual Estate Planning Newsletter, and focuses on foreign matters. We urge you to review this installment to ensure that your 2016 estate and tax planning is in order. ...more

Blank Rome LLP

2015 Estate and Tax Planning

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Blank Rome’s annual estate planning newsletter discusses certain concepts and techniques that we hope may be of interest to our clients and friends....more

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