News & Analysis as of

Offshore Funds Internal Revenue Service Tax Evasion

Allen Barron, Inc.

The Risks of an IRS Quiet Disclosure

Allen Barron, Inc. on

What are the risks of an IRS quiet disclosure? Is there a formal IRS process known as a "quiet disclosure," and does the IRS honor this strategy for amended tax returns?...more

Allen Barron, Inc.

What is the IRS Offshore Voluntary Disclosure Program?

Allen Barron, Inc. on

What is the IRS Offshore Voluntary Disclosure Program and who is it designed to help? What are the guidelines for voluntary disclosure to the IRS and who is eligible to apply? The IRS Offshore Voluntary Disclosure...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

Lerch, Early & Brewer

Tenth Circuit Affirms Deficiencies, Penalties for Offshore Income

Lerch, Early & Brewer on

Harrington v. Commissioner - In Harrington v. Commissioner of Internal Revenue, George S. Harrington (Harrington) challenged tax deficiencies and fraud penalties assessed for tax years 2005 through 2010. Originally...more

Foodman CPAs & Advisors

El IRS Advierte A Los Contribuyentes Contra Las Estrategias De Evasión Fiscal

El IRS concluyó su lista de Estafas de la Docena Sucia (“Dirty Dozen”) del 2022 recomendando a los contribuyentes a estar atentos y evitar ser engañados por las estrategias de evasión fiscal....more

BakerHostetler

Per-Account or Per-Form Penalty?

BakerHostetler on

Key Takeaways: ..The law regarding computation of FBAR penalties is unclear. ..The United States Supreme Court has agreed to hear a case to settle a conflict among the circuit courts. ..Until the Supreme Court...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

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

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

Foodman CPAs & Advisors

El IRS Está En Una Misión De Reducir La Brecha Fiscal

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

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

Foodman CPAs & Advisors

Closing A Foreign Bank Account Will Not Solve A Taxpayer’s Disclosure Problem

IRS is interested in U.S. Taxpayer financial accounts everywhere in the world.  If the IRS learns that a Taxpayer has undisclosed reportable accounts or income before a US Taxpayer reports them, the Taxpayer can face serious...more

Oberheiden P.C.

Eleven of the IRS's Enforcement Priorities During the 2021 Tax Season

Oberheiden P.C. on

It is tax season once again. While the Internal Revenue Service (IRS) has extended this year’s filing deadline to May 17, 2021 for individuals, businesses must still file by April 15, and all U.S. taxpayers must ensure that...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

Foodman CPAs & Advisors

“Complexity will not hide crime from law enforcement,” California U.S. Attorney on Brockman Indictment

The U.S. Department of Justice (DOJ) 39 count indictment charging Robert T. Brockman, with tax evasion, wire fraud, money laundering, and other offenses, demonstrates that the DOJ is committed to the investigation and...more

Foodman CPAs & Advisors

Beware of FATCA Notices of Default After FATCA Certification Deadlines!

Foodman CPAs & Advisors on

Under FATCA, an Event of Default (EOD) will occur if an Entity fails to perform required material obligations with respect to the due diligence, verification, withholding, or reporting FATCA requirements, or if the IRS...more

Foodman CPAs & Advisors

¡Tenga cuidado con las notificaciones de incumplimiento de FATCA después de las fechas límite de certificación de FATCA!

Foodman CPAs & Advisors on

Bajo FATCA, un Evento de Incumplimiento (“Event of Default o EOD”) ocurrirá si una Entidad no cumple con las obligaciones materiales requeridas con respecto a los requisitos de diligencia debida, verificación, retención o...more

Foodman CPAs & Advisors

The OVDP is now the VDP

There was an IRS termination of the Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018. On November 20, 2018, following the OVDP notice of termination, there was a release of a Memorandum announcing the...more

Foodman CPAs & Advisors

FBAR Penalties: Is it per Account or per Violation?

U.S. Taxpayers (includes a citizen, permanent resident, corporation, partnership, limited liability company, trust and estate) are required to file a Report of Foreign Bank and Financial Accounts (FBAR) if they have...more

Foodman CPAs & Advisors

An IRS “John Doe” Summons is a Powerful Weapon that can Puncture Attorney-Client Privilege

An individual that provides information to an attorney may normally assume that the information provided to the attorney will be kept confidential under the attorney-client privilege.  That said, according to the Internal...more

Lowndes

Don’t Forget to File Your Foreign Bank Account Return

Lowndes on

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

Foodman CPAs & Advisors

IRS: Las Cuentas Financieras “Offshore” NO pasarán Inadvertidas

El 15 de marzo del 2019, el IRS informó que la ocultación de dinero o activos en cuentas extraterritoriales (“offshore”) no declaradas permanece en la lista de las estafas tributarias conocidas come la Docena Sucia o "Dirty...more

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