News & Analysis as of

Foreign Financial Accounts

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

FinCEN Announces Yet Another FBAR Filing Extension For Certain Financial Professionals

by Fox Rothschild LLP on

Last week the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) again extended the deadline for certain financial professionals to file foreign bank accounting reporting forms known as FBARs. In FinCEN...more

Paradise Papers, Panama Papers…. The Message is Clear: Report Offshore Accounts!

by Foodman CPAs & Advisors on

First, the Panama Papers, and now… the Paradise Papers. The Paradise Papers contain the names of approximately 31,000 US citizens, including entities, or persons with US addresses....more

What If You Are Ineligible For The Offshore Voluntary Disclosure Program? Attorney Proffers versus Quiet Disclosures

by Sanford Millar on

Since the beginning of the current Offshore Voluntary Disclosure Programs (OVDP) in 2009 tens of thousands of U.S. taxpayers have come forward to report previously undisclosed foreign financial accounts. The addition of the...more

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

Información tributaria de 36 países ya está en Colombia

by Holland & Knight LLP on

Por medio del comunicado de prensa No. 149 del 9 de octubre, la DIAN informó que en desarrollo de los Acuerdos de Intercambio de Información vigentes y de la Ley FATCA, recibió la información correspondiente al año 2016, de...more

With Tensions Rising, the United States Imposes Additional Sanctions on North Korea

by Jones Day on

In Short - The Situation: Over the past several months, North Korea has engaged in several activities, particularly relating to missile and nuclear testing, that violate several United Nations resolutions and that...more

Are you a Taxpayer identified by IRS for not Reporting Offshore Financial Assets?

by Foodman CPAs & Advisors on

Taxpayers with unreported foreign financial assets and income run the risk of having the Government determine if their conduct was willful or non-willful. The definition of “Willful" or "non-willful” in Taxpayer’s conduct...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

Applying Overpayments of Tax to Tax and the Offshore Penalty in the OVDP Program

by Charles (Chuck) Rubin on

The OVDP program allows taxpayers to remedy deficient disclosure filings relating to offshore accounts for a fixed penalty amount. As part of the program, taxpayers must file either original or amended tax returns which...more

Government Refuses to Define "willfulness" for FBAR Purposes

by Sanford Millar on

Whether a taxpayer's conduct in failing to report foreign financial accounts is "willful" or "non-willful" makes a huge difference in penalty determination. However the government refuses to publish a definition of...more

Getting Into Compliance with Your Foreign Account Reporting, Part II

by Moskowitz LLP on

In Part I, we listed some of the penalties associated with the failure to report foreign accounts, and what is widely regarded as the best option for coming into compliance – the Offshore Voluntary Disclosure Program (OVDP)....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

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

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

The High Cost of Being Noncompliant with the Internal Revenue Code

by Holland & Knight LLP on

The IRS currently offers the following five programs for noncompliant taxpayers: (i) the Offshore Voluntary Disclosure Program (OVDP), (ii) Streamlined Domestic Offshore Procedures, (iii) Streamlined Foreign Offshore...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

Post-Election Outlook: A New, Unpredictable World

In a shock to investors and political analysts around the world, Donald J. Trump won the 2016 Presidential election, putting the Republican Party in charge of the White House and Congress for the first time in a decade. Even...more

IRS Agrees to Increased Enforcement of IRS's Offshore Voluntary Disclosure Program

by Moskowitz LLP on

In a report issued to the Internal Revenue Service International Division and Criminal Division, the Treasury Inspector General for Tax Administration (TIGTA) found that taxpayers trying to avoid criminal charges and...more

Upcoming FATCA Deadlines

by Foley Hoag LLP on

As noted in the Foley Adviser dated April 14, 2016, there are several upcoming FATCA-related deadlines, two of which are right around the corner: ..June 30, 2016: Foreign Financial Institution Due Diligence for...more

El FBAR y La Declaración de Impuestos Se Sincronizan

by Foodman CPAs & Advisors on

La presentación de la declaración de impuestos (el 15 de Abril para los individuos) y el formulario de FinCEN -Informe 114, conocido como FBAR (el 30 de Junio para todos los contribuyentes) no estaban alineadas, y no existía...more

The FBAR and Tax Return are now in Sync!

by Foodman CPAs & Advisors on

The filing of the tax return (April 15 for individuals) and Report FinCEN Form 114, known as FBAR (June 30 for all taxpayers) were not aligned, and that there wasn’t an extension available for the FBAR. This disconnect is...more

FBAR: 2015 Reports Due by June 30, 2016

by Foley Hoag LLP on

Every U.S. person (including both individuals and entities, as discussed below) that had a financial interest in, or signature or other authority over, one or more foreign financial accounts during 2015 must electronically...more

Online Poker: A New Way to Bank?

by Ifrah PLLC on

In light of Tax Day (note that it’s on the 18th of April this year due to a holiday on the 15th) we want to point out a curious ramification from a federal case concerning online gambling, tax reports, and foreign...more

When Offshore Asset Protection Fails

by Sanford Millar on

What happens when The IRS attacks your offshore asset protection plan? The simple answer is you may face a variety of civil and criminal investigations and penalties. What constitutes an offshore asset protection plan?...more

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