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Income Taxes › Offshore Funds

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... more +
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 -
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

Foodman CPAs & Advisors

IRS Voluntary Disclosure Practice

Foodman CPAs & Advisors on

Taxpayers that have willfully failed to comply with tax or tax-related obligations may be able to resolve their non-compliance and limit their exposure to criminal prosecution by filing an application to the IRS Voluntary...more

Allen Barron, Inc.

What is an FBAR and What Foreign Financial Information Are You Required to Report?

Allen Barron, Inc. on

What is an FBAR, and what information is a U.S. taxpayer required to report to the U.S. Government and the IRS? There are many questions about the requirements for U.S. taxpayers with foreign accounts, investments, and...more

Allen Barron, Inc.

When to Consider the IRS Voluntary Disclosure Program or VDP

Allen Barron, Inc. on

Are you wondering when a US taxpayer should consider the IRS Voluntary Disclosure Program or VDP? Are you concerned about unreported or under-reported income, financial accounts, assets, investments, cryptocurrency or...more

Allen Barron, Inc.

The Tax Consequences of Offshore Mutual Funds for US Expats and Taxpayers

Allen Barron, Inc. on

What are the tax consequences of offshore mutual funds for US expats and taxpayers? US expatriates have faced a substantial number of challenges over the past several years as a result of FATCA. It can be hard to simply open...more

McDermott Will & Emery

Weekly IRS Roundup April 8 – April 12, 2024

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 8, 2024 – April 12, 2024. April 8, 2024: The IRS released Internal Revenue Bulletin 2024-15,...more

Proskauer - Tax Talks

Tax Court holds that an offshore fund is engaged in a U.S. trade or business

Proskauer - Tax Talks on

On November 15, 2023, the U.S. Tax Court held in YA Global Investments v. Commissioner that a non-U.S. private equity fund (YA Global) with a U.S. asset manager that bought equity and convertible debt of U.S. portfolio...more

Allen Barron, Inc.

Could an Upcoming Supreme Court Case Significantly Change US Tax Law?

Allen Barron, Inc. on

Could a Supreme Court of the United States (SCOTUS) case significantly change US tax law? We are closely watching the developments in Moore v United States as it carries significant issues regarding “realized” versus...more

Gray Reed

FBAR Penalty Defenses and Techniques: The Wrong “Willful” Penalty Computation

Gray Reed on

On September 8, 2023, the IRS issued a News Release suggesting that FBAR compliance investigations and audits would heat up in the near future.  For those unfamiliar with FBARs, federal law requires United States persons to...more

Proskauer Rose LLP

UK Tax Round Up - March 2023 - 2

Proskauer Rose LLP on

Welcome to March’s edition of the UK Tax Round Up. This month’s edition features comments on the recent Spring Budget together with a summary of some recent case law involving VAT due on services provided to ex-VAT group...more

Cadwalader, Wickersham & Taft LLP

Supreme Court Hands Taxpayers a Victory in FBAR Penalty Case

Cadwalader, Wickersham & Taft LLP on

Taxpayers recently won a significant victory at the Supreme Court in a penalty case involving a non-willful failure to file a Report of Foreign Bank and Financial Accounts (“FBAR”) under the Bank Secrecy Act (the “BSA”)....more

Polsinelli

Major Win For Taxpayers: SCOTUS Limits FBAR Penalties to Per Report Not Per Financial Account

Polsinelli on

After years of litigation, the United States Supreme Court, in Bittner v. United States, 598 U.S. ____ (2023), determined that the penalty for a non-willful failure to file a Report of Foreign Bank and Financial Accounts...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

Holland & Knight LLP

Willful or Non-Willful? That Is the Question: IRS Rejects Non-Willful Certification

Holland & Knight LLP on

In Flint v. United States, 2022 WL 3593826 (Fed. Cl. 2022), the court held that the executors of an estate could not recover a six-figure "Title 26 miscellaneous offshore penalty" (MOP) the decedent paid to the Internal...more

Freeman Law

Is My Foreign Retirement Account Subject to IRS Information Return Reporting (FBAR, 3520, etc.)?

Freeman Law on

United States citizens and residents[i] are subject to federal income tax on their worldwide income. For example, even if a United States citizen permanently relocates to a foreign country, he or she will generally continue...more

Miller Nash LLP

Today in Tax: Foreign Account Reporting Requirements and Divisive Tax-Free Reorganizations

Miller Nash LLP on

FBAR Noncompliance Leads to More Severe Penalties in the 5th Circuit Penalties for FBAR violations can be severe if applied on a per-account basis, as opposed to a per-form basis. However, a taxpayer with “reasonable cause”...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

Yet Another Streamlined Filing Turns into a Criminal Indictment, Implicating Former CPA and Businessman

Freeman Law on

A recent IRS Criminal Investigation press release announced an indictment against a businessman charged with defrauding the United States by not disclosing offshore assets, failing to report income to the IRS, and submitting...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

Freeman Law

Federal Court Imposes Willful FBAR Penalties on Long-Time CPA

Freeman Law on

In a recent decision, a federal district court found that a long-time CPA/tax-return preparer recklessly failed to file FBARs to disclose several foreign financial accounts. As avid readers of our Insights are aware, many...more

Foodman CPAs & Advisors

El IRS Está En Una Misión De Reducir La Brecha Fiscal

Foodman CPAs & Advisors on

La diferencia entre el monto del impuesto adeudado por los Contribuyentes para un año determinado y el monto que realmente se paga oportunamente para ese mismo año se conoce como “Brecha Fiscal Bruta” (“Tax Gap”). El IRS...more

Foodman CPAs & Advisors

IRS Is On A Mission Is To Reduce The Tax Gap

Foodman CPAs & Advisors on

The difference between the amount of tax owed by Taxpayers for a given year and the amount that is actually paid timely for that same year is known as the “Gross Tax Gap”. The IRS looks at this number as an estimate of the...more

Holland & Knight LLP

Large Corporations and Wealthy Taxpayers Beware: The Taxman is Coming

Holland & Knight LLP on

Internal Revenue Service (IRS) Commissioner Chuck Rettig on April 13, 2021, told a U.S. Senate panel that the tax gap in the U.S. may total $1 trillion per year. In his view, the increase from prior estimates is due, in part,...more

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