News & Analysis as of

Offshore Funds Foreign Financial Accounts

Allen Barron, Inc.

IRS Updated Streamlined Filing Compliance Procedures

Allen Barron, Inc. on

What do you need to know about the IRS updated Streamlined Filing Compliance Procedures or "Streamlined Procedures?" Are you concerned about unreported or under-reported offshore income or assets? Are there accounts you...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

Freeman Law

Flint Demonstrates the Risks in Trying to Make a Willful IRS Streamlined Filing Non-Willful

Freeman Law on

Federal case and after federal case continues to come out providing real-life examples of the pitfalls of filing a Streamlined Filing Compliance Procedure (“SFCP”) with the IRS when the facts suggest willfulness rather than...more

Freeman Law

Challenging FBAR Penalties in Federal Court: FBAR Litigation

Freeman Law on

In most cases, IRS exam initiates FBAR assessments. And, after an IRS examiner determines that an FBAR penalty is appropriate, taxpayers are generally afforded pre- or post-assessment appeals rights with the IRS Independent...more

Freeman Law

IRS Gets Green Light to Seek Information from Third Parties Regarding Panama Offshore Legal Services

Freeman Law on

On July 29, 2021, the United States Attorney for the Southern District of New York, the Assistant Attorney General for the Department of Justice Tax Division, and the IRS Commissioner all announced that a federal court in New...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

Polsinelli

Timely FBAR Filing as Important as Ever Following Circuit Court Decisions

Polsinelli on

Last week the Ninth Circuit issued a win for taxpayers in US v. Boyd, limiting penalties for non-willful violations of the requirement to file a Report of Foreign Bank and Financial Accounts (FBAR). ...more

Dorsey & Whitney LLP

Often Overlooked Exception to Withholding and Reporting Requirements under FATCA

Dorsey & Whitney LLP on

An often overlooked exception to U.S. withholding taxes may result in a lower overall U.S. tax burden. The Foreign Account Tax Compliance Act (“FATCA”) was enacted in an effort to ensure that U.S. taxpayers could not...more

Blank Rome LLP

FinCEN Announces Plan to Require U.S. Persons to Report Foreign-Held Virtual Currency on Foreign Bank Account Reporting Forms

Blank Rome LLP on

Individuals who own virtual currency should consult with a tax professional to determine if their virtual currency is subject to a reporting requirement. On December 31, 2020, the Financial Crimes Enforcement Network...more

Oberheiden P.C.

Is “Fraud Tourism” The Next Big Thing? How U.S. Government Money Ends Up Abroad

Oberheiden P.C. on

How much of the Paycheck Protection Program (“PPP”) will end up in the hands of bad actors? With several hundreds of billions of dollars in the PPP bucket, fraud, misuse, and misdirection of funds is already being identified...more

Foodman CPAs & Advisors

IRS Continues to Cross-Reference Foreign Financial Accounts and Assets

IRS holds information that is sourced from the FATCA reports submitted by Foreign Financial Institutions (FFI) (on Form 8966 - FATCA Report) and by Individual US Taxpayers that have reporting obligations via Form 8938...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Recent IRS Interim Guidance Provides That It Is Not Too Late For Your Willful Clients To Voluntarily Disclose Their Offshore...

The Internal Revenue Service has had a long-standing practice of providing taxpayers with potential criminal exposure a means to come into compliance with the law and potentially avoid criminal prosecution through the making...more

Foodman CPAs & Advisors

Disclosing Voluntarily to the IRS to potentially avoid Criminal Prosecution is still an Option for Taxpayers, but with some...

On September 28, 2018, the IRS closed the Offshore Voluntary Disclosure Program (2014 OVDP). The 2014 OVDP (and prior 2011 and 2009 programs) had the purpose of providing Taxpayers that WILLFULLY failed to report foreign...more

Fox Rothschild LLP

The New IRS Voluntary Disclosure Regime: Worth The Price Of Admission?

Fox Rothschild LLP on

Following the termination last fall of its immensely successful Offshore Voluntary Disclosure Program (OVDP), the Internal Revenue Service (IRS) has announced a new regime to govern all voluntary disclosures regarding tax...more

Dickinson Wright

Updated Voluntary Disclosure Practice Rules

Dickinson Wright on

On September 28, the IRS ended its 2014 Offshore Voluntary Disclosure Program (“OVDP”). The IRS issued a memorandum—dated November 20, 2018—to announce its new Updated Voluntary Disclosure Practice rules. The IRS memorandum...more

Orrick, Herrington & Sutcliffe LLP

IRS Outlines New Process for Voluntary Disclosures

On November 29, 2018, the Internal Revenue Service (the "IRS") published a memorandum (the "Memorandum") dated November 20, 2018, outlining the new process for all voluntary disclosures, both domestic and offshore (the "New...more

Foodman CPAs & Advisors

Offshore Accounts Today Equal Transparency

Foodman CPAs & Advisors on

The days of avoiding taxes through hiding money or assets in unreported offshore accounts are gone. Nonetheless, there are still taxpayers with undeclared offshore accounts, as well as the banks and bankers that are...more

Blank Rome LLP

IRS Announces New Voluntary Disclosure Procedures

Blank Rome LLP on

The Internal Revenue Service (“IRS”) has released a memorandum outlining new procedures for making voluntary disclosures of tax noncompliance, just two months after their 2014 Offshore Voluntary Disclosure Program had ended....more

Rosenberg Martin Greenberg LLP

Offshore Update: IRS Releases Memorandum Addressing Updates to Voluntary Disclosure Practice After Closing Offshore Voluntary...

Now, More than Ever, Taxpayers with Lingering Offshore Tax Non-Compliance Must Seek Professional Assistance - On November 20, 2018, the Internal Revenue Service (“the Service”) released a memorandum containing important...more

Blank Rome LLP

IRS Not Contemplating Separate Voluntary Disclosure Program to Assist Taxpayers Who’ve Not Reported Cryptocurrency Income

Blank Rome LLP on

A separate voluntary disclosure program to assist a significant number of taxpayers who have failed to report income resulting from transactions involving virtual currency will likely not be available according to a recent...more

Fox Rothschild LLP

Despite Closure Of OVDP, Offshore Tax Evasion Crackdown Marches On

Fox Rothschild LLP on

On September 29, 2018, the Internal Revenue Service closed for good the long-running Offshore Voluntary Disclosure Program (OVDP), its hugely successful tax amnesty program for undisclosed offshore financial assets. Since...more

Foodman CPAs & Advisors

Do I have to file an FBAR if I own Cryptocurrency? Not clear!

Both the American Bar Association (ABA) and the American Institute of Certified Public Accountants (AICPA) have written letters (3/19/18 for the ABA and 5/30/18 for the AICPA) to the IRS to obtain further definition and...more

Foodman CPAs & Advisors

Let’s Understand Filing FBARs

The jurors in the Paul Manafort case had questions regarding the complex Foreign Bank Account Reports (FBARs) regulations. This was evidenced by the jury’s questions to the judge addressing the responsibility to file an FBAR...more

Ballard Spahr LLP

DOJ Secures First Ever Conviction for Violating FATCA

Ballard Spahr LLP on

The Department of Justice (“DOJ”) has secured its first conviction ever under the Foreign Account Tax Compliance Act, or FATCA, through the guilty plea of Adrian Baron, a former executive of Loyal Bank Ltd., a bank with...more

Foodman CPAs & Advisors

IRS ENDS OVDP right when some Taxpayers GET IT!

On March 13, 2018, IRS announced the termination of the Offshore Voluntary Disclosure Program (OVDP) as of September 28, 2018 (Notice IR-2018-52). ...more

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