News & Analysis as of

Foreign Banks Internal Revenue Service

Will Your Offshore Bank or Cryptocurrency Exchange Turn You In to the IRS?

by Sanford Millar on

Well the results of the Foreign Account tax Compliance Act (“FATCA”) are coming in and the IRS will be stepping up audit of “holder” of unreported account. The exam targets will be U.S. taxpayers who own or control foreign...more

Treasury Hints That Regulatory Review May Target FATCA Regulations

by Fox Rothschild LLP on

In a report to the President recommending actions to eliminate or mitigate burdens imposed on taxpayers by eight specific tax regulations, the Treasury Department indicated that it is considering possible reforms of...more

FATCA Update: FFI Agreement Renewal Function Now Available

by Fox Rothschild LLP on

The Internal Revenue Service announced today that its FATCA FFI Registration system has been updated to allow foreign financial institutions to renew their FFI agreement with the IRS. Those financial institutions that are...more

Traps for the Unwary: Are Financial Institution receiving adequate FATCA consulting and training?

by Foodman CPAs & Advisors on

FATCA is Chapter 4 of the Internal Revenue Code (IRC). It conscripts Foreign Financial Institutions (FFIs) to act as reporting and withholding agents for the U.S. Government. To enforce its conscription, it contains a...more

US Banks wanting to be ahead of the FATCA game must master international tax compliance

by Foodman CPAs & Advisors on

The terms FDAP (Fixed, Determinable Annual and Periodical Income) and ECI (Effectively Connected Income) are expansive terms. They are the backbone behind the tax withholding, and reporting requirements imposed on US Banks...more

Structured Thoughts: News for the financial services community - Special Issue

Final TLAC Rules and Structured Products - On December 15, 2016, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued its final rules regarding long-term debt and total loss absorbing...more

US FATCA: Deadline to Register Sponsored Entities Approaching

by Morgan Lewis on

Sponsoring entities should evaluate which of their sponsored entities should be registered via the IRS registration portal....more

$100 Million FBAR Penalty - Ouch

by Charles (Chuck) Rubin on

Taxpayers who fail to file Reports of Foreign Bank and Financial Accounts (FBARs) disclosing their non-U.S. accounts can suffer a 50% penalty on the balance of the unreported accounts. In one of the largest penalties I have...more

Singapore’s Banking Secrets - Not So Secret Anymore

by K&L Gates LLP on

Since 2008, the U.S. Government has largely focused its enforcement actions against Swiss banks that may have assisted U.S. taxpayers in evading federal taxes. In August 2013, the Department of Justice (“DOJ”) introduced the...more

US Internal Revenue Service and US Treasury Department Issue Anti-Inversion Regulations

by Shearman & Sterling LLP on

The US Internal Revenue Service issued a proposal under Section 385 of the Internal Revenue Code with respect to the treatment of instruments issued by corporations in related-party transactions as debt or equity for federal...more

IRS Uses New Tactic to Expand Efforts to Combat Offshore Tax Evasion

In a search for financial records of a U.S. taxpayer who allegedly parked undeclared income offshore, the Internal Revenue Service (IRS) and the U.S. Department of Justice (DoJ) are seeking to enforce a summons against a U.S....more

Cross-Border Banking and Out-of-this-World Penalties - Dealing with the IRS when you have Foreign Bank Accounts

A United States citizen or resident that owns (or has signatory authority over) an account at a foreign bank with a value in excess of $10,000 annually must file a Report of Foreign Bank and Financial Account (or “FBAR”) with...more

Global Tax Enforcement in 2016: What You Need to Know

by BakerHostetler on

The investigation and prosecution of tax evasion has, in the past decade, grown from a specialized subcategory of law enforcement into a first-tier policy concern for the international community. Financial institutions,...more

FATCA Update: Treasury Relaxes September 30 Deadline for Model 1 IGA Jurisdictions to Exchange Tax Information

by Blank Rome LLP on

With less than two weeks remaining until many countries are required to exchange tax information with the U.S. pursuant to the Foreign Account Tax Compliance Act (FATCA), the U.S. has agreed to provide partner jurisdictions...more

Bad Bad, Bad Penalty, Bad OVDP Policy

by Sanford Millar on

There are now 50 foreign financial institutions on the IRS list of "bad banks" The list is published at the following link...more

Two More Banks Reach Resolutions Under Justice Department’s Swiss Bank Program

by Blank Rome LLP on

On June 3, 2015, the Justice Department announced that two more Swiss banks, Rothschild Bank AG and Banca Credinvest SA, reached resolutions under the DOJ Swiss Bank Program. Yesterday’s announcement brings the total Swiss...more

What To Do If You Have Delinquent International Information Tax Returns

A U.S. taxpayer with international holdings and interests may not be fully compliant with U.S. tax reporting obligations even though they have currently reported all foreign source income on their annual tax return, filed...more

Foreign Account Holders: Don’t Forget to File Your FBARs by the June 30th Deadline

Now that the April 15th deadline has passed and tax season is over, most taxpayers can breathe a sigh of relief. At least for another year. For others with overseas financial accounts and interests, one more reporting hurdle...more

Foreign Banks and Bankers Face New Risks From Swiss Bank Amnesty

by Latham & Watkins LLP on

The first non-prosecution agreement signals expanded US tax enforcement opportunities at home and abroad. The US Department of Justice (DOJ) has announced the first non-prosecution agreement (NPA) with BSI, SA, (BSI)...more

Dealing with Erroneous FATCA Inquiries

A foreign bank asks our client to provide information that the bank is not required to provide IRS under FATCA. There are two possibilities. Our client can provide the information or our client can choose not to provide the...more

FATCA Notebook: Former IRS Chief, Taxpayer Advocate Criticize FATCA; Switzerland Moves Toward Greater Transparency

by Blank Rome LLP on

First, former acting IRS Commissioner Steven Miller speaks out against FATCA and suggests that the benefits of the new information reporting regime imposed by FATCA may not outweigh its costs. An article published by...more

Offshore Tax Enforcement Update: IRS Unveils Major Changes to Voluntary Disclosure Program

by Blank Rome LLP on

Since the 1970s, U.S. taxpayers with foreign banks accounts have been required to annually report their foreign bank account information to the Department of Treasury on a Report of Foreign Bank and Financial Accounts...more

June 30 Deadline Approaches for Mandatory E-File FBAR Reporting

by McDermott Will & Emery on

2014 presents particular challenges with respect to FBAR, the Report of Foreign Bank and Financial Accounts, for certain U.S. persons with interests in or signature authority over assets exceeding $10,000 held outside the...more

Bitcoin Reportability and Taxation

by Holland & Knight LLP on

June 30 is the deadline for taxpayers with a connection to foreign financial accounts to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR). As this is the first year in which all FBARs must be...more

DOJ Secures Verdict in Excess of $2 Million for Failure to File FBARs

On Wednesday, May 28, 2014, a jury in Miami issued a verdict against a taxpayer for $2.2 million in fees, interest, and civil penalties for willfully failing to file foreign bank account reports (FBARs) for his Swiss bank...more

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