News & Analysis as of September 20, 2024

Foreign Banks

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

Taxpayers Abroad are Underserved and Challenged

Foodman CPAs & Advisors on 9/6/2024

The National Taxpayer Advocate 2023 Annual Report to Congress highlights how Taxpayers abroad are underserved and continue to face challenges in meeting their U.S. tax obligations. As a result, the National Taxpayer Advocate...more

Estate and Tax Planning for US Expatriates

Allen Barron, Inc. on 11/16/2023

What are the most important elements of estate and tax planning for US expatriates? Are you planning to move out of the United States? Are you a US taxpayer who lives and works outside of the country? What are some of the...more

IRS Publishes Final Regulations on IBOR Transition for Published Rate Elections

Cadwalader, Wickersham & Taft LLP on 7/28/2023

On June 29, 2023, the IRS published final regulations that provide the appropriate reference rate to be used by a foreign bank that elects to use a published rate to determine the amount of excess interest expense allocable...more

Can The IRS Collect Assets Abroad?

Foodman CPAs & Advisors on 8/24/2022

The answer to the question “Can the IRS Collect Assets Abroad”” is yes, based on the Office of Chief Counsel Internal Revenue Service memorandum dated February 24, 2022. The memorandum discusses the IRS Collection Procedures...more

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on 12/13/2018

Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

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

Partridge Snow & Hahn LLP on 2/9/2016

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

June 30 Deadline Approaches for Mandatory E-File FBAR Reporting

McDermott Will & Emery on 6/25/2014

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

DOJ Offshore Enforcement Update: In Landmark Case, Credit Suisse Pleads Guilty, Agrees to Pay $2.6 Billion Penalty; Swiss Bank...

Blank Rome LLP on 5/21/2014

Yesterday, the Department of Justice announced that Credit Suisse AG pleaded guilty to having assisted U.S. taxpayers in evading the payment of U.S. taxes and agreed to pay a penalty of $2.6 billion. Deputy Attorney General...more

FBAR and Form 8938 Assistance Provided by Treasury

Holland & Knight LLP on 1/30/2014

There are a multitude of information returns that United States taxpayers may need to file if they own foreign assets or have foreign investments. Two of these forms are the FBAR (Foreign Bank Account Report) and Form 8938...more

FBAR E-Filing and Signature Authority: What You Need to Know

Holland & Knight LLP on 1/28/2014

Much has been written about the IRS's dogged pursuit of taxpayers with unreported foreign accounts. These accounts are reported on the Report of Foreign Bank and Financial Accounts (FBAR) when a taxpayer has a financial...more

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