Deadline to Reporting Foreign Accounts Approaches For the past several years, the FBAR has been on automatic extension. This means that U.S. Taxpayers worldwide have until October 15th to file the FBAR, even if they did not request an extension for their tax return. For most […]
For Noncompliant Taxpayers with Foreign Accounts The Internal Revenue Service has significantly increased enforcement for offshore disclosure and foreign account filing non-compliance penalties. In years past, the IRS did not routinely penalize U.S. Taxpayers for failing to report their foreign accounts — and oftentimes, the IRS […]
The Risk of Disclosing Foreign Account Information to Accountants When U.S. Taxpayers across the globe learn that they are out of compliance with the IRS and FinCEN for failing to report their foreign accounts, assets, investments, trusts, or entities, oftentimes their immediate knee-jerk reaction is to […]
How Long Should I Way Before Reporting Foreign Accounts? When a U.S. Person Taxpayer such as a U.S. citizen, Lawful Permanent Resident, or foreign national who meets the Substantial Presence Test learns that they are out of offshore tax and reporting compliance for not reporting their […]
When IRS Changes Course on International Penalty Enforcement Over the past several years, the Internal Revenue Service has significantly increased enforcement of international-related tax and reporting compliance matters. There are many different international information reporting forms that a U.S. Taxpayer may have to file when they […]
What is IRS Form 8621 While there are many complicated aspects to international tax and reporting, the IRS requirements for having to report Passive Foreign Investment Companies (PFIC) are some of the most daunting and complex. Technically, the PFIC is an acronym for Passive Foreign Investment […]
Form 8833 Tax Treaty Position to the IRS Taxpayers who are Lawful Permanent Residents and non-permanent residents who qualify as U.S. persons for tax purposes under the substantial presence test are taxed on their worldwide income similar to U.S. citizens. This is different from how most […]
A Beginner’s Guide to Form 5471 Foreign Corporations With the globalization of the U.S. economy, it is becoming increasingly common for U.S. Taxpayers to have an ownership interest in a foreign corporation — which may then require the Taxpayer to file Form 5471 to report their […]
A Form 8938 Beginner’s Guide to Foreign Assets (FATCA) When it comes to having to report foreign accounts and assets on various international information reporting forms to the IRS, Form 8938 is a relative newcomer to the world of international tax. The Form 8938 is like […]
Overview of Foreign Pension for U.S. Taxpayers It is very common for U.S. Taxpayers who are considered U.S. Persons for tax purposes to have worked or been employed in a foreign country and accumulated foreign employment retirement/pension over their lifetime — or possibly invested in a […]
Form 3520 Penalties and Abatement Procedure In recent years, the Internal Revenue Service has significantly increased enforcement of the Form 3520 filing requirements. Form 3520 is used for several different reasons, but one of the primary purposes of the form is for U.S. Persons to report […]
IRS Form 3520 CP15 Notice Penalty Response A U.S. taxpayer may have to file many different international information reporting forms each year to disclose their foreign accounts, assets, investments, businesses, gifts, and trusts to the IRS. One of the most common types of international information reporting […]
The Threshold Requirements For Form 8938 While there are many different international information reporting forms that a U.S. Taxpayer may have to file, Form 8938 has become one of the most common. IRS Form 8938 refers to the reporting of Specified Foreign Financial Assets in accordance […]
Which U.S. Tax Forms to File for Foreign Retirement Plans It is very common for U.S. taxpayers who are considered U.S. persons for tax purposes to have worked or been employed in a foreign country and accumulated foreign retirement/pension over their lifetime — or possibly invested […]
What are the Form 3520-A Filing Requirements? When it comes to international tax and reporting, foreign trust tax and reporting are two of the most complicated aspects of annual foreign investment compliance. This is because of many different reasons, such as: What is a foreign trust? […]
National Taxpayer Advocate Protests IRS International Penalties For many years, our international tax law team has written numerous articles on the absolute absurdity of how the Internal Revenue Service penalizes taxpayers for the failure to report certain international information reporting forms, such as Form 3520 and […]
A Guide to Legally Moving Money Offshore Especially for taxpayers who may be new to the United States tax system, it can come as a shock and a surprise to learn that not only does the United States tax individuals on their worldwide income, but they […]
Criminal Tax Questions and Answers Oftentimes, when U.S. taxpayers make a mistake involving international tax and reporting, their knee-jerk reaction is to assume that they may have done something criminal and that the IRS Special Agents will be banging down their doors, but this is rarely […]
Was Your Streamlined Disclosure Rejected? When it comes to the Internal Revenue Service and offshore disclosure, many U.S. taxpayers can qualify to safely get into international tax and reporting compliance for previously undisclosed foreign accounts, assets, investments, and income – and regain their peace of mind […]
Tax Court Rules for IRS on $40 Million Innocent Spouse Claim In the recent case of Strom, the petitioner is the spouse of a high-income earner who petitioned the U.S. Tax Court for innocent spouse relief of more than $39 million in deficient taxes due to […]
Example of an IRS Audit for Expatriation Expatriation is the process in which a U.S. Citizen (USC) or a Long-Term Lawful Permanent Resident (LTR) formally renounces their U.S. citizenship or terminates their Lawful Permanent Resident status. For some taxpayers, the expatriation process is relatively painless. Even […]
The IRS Intensifies Focus on Offshore Tax Fraud Investigations In recent months, the Internal Revenue Service has issued various warnings to U.S. Taxpayers worldwide involved in potentially abusive and unscrupulous tax schemes. Some of the current focuses of the IRS include: Sham Trust Arrangements, Improper Use […]
Contempt for Not Repatriating Foreign Assets In this case, it is important to note that the Foreign Bank Account Reporting penalties did not stem from a criminal FBAR matter. Rather, it was a civil FBAR case that seemingly went off the rails — due to a […]
Out of all the different international information return filing requirements, Form 8938 is a relative newcomer to the world of foreign account and asset reporting. The Form 8938 is the Statement of Specified Foreign Financial Assets under 26 U.S.C. 6038D and it is filed each […]
3 Abusive Tax Arrangements While the Internal Revenue Service has a reputation for perpetually being the bad guy and going after U.S. taxpayers for every mistake they make on their taxes, there is another aspect of the IRS — which is to protect taxpayers. One of […]
The Court Upheld Form 5471 Penalties Unfortunately, U.S. taxpayers across the globe who are required to report their foreign assets to the IRS on various international information reporting forms were dealt a heavy blow by the DC Court of Appeals, when the Appellate Court reversed the […]
Deficiency Procedures Do Not Apply to Form 3520 For the past several years, the Internal Revenue Service has specifically targeted international information reporting noncompliance as a key enforcement priority. Oftentimes, U.S. taxpayers are penalized extensively for their failure to report foreign accounts, assets, investments, trusts, and […]
Choosing the Best Foreign Accounts Disclosure Lawyer Ever since the Internal Revenue Service increased its enforcement of offshore disclosure and compliance matters, many less experienced attorneys have jumped in the mix making false representations about their experience — and leading taxpayers astray. And, when these attorneys […]
IRS Foreign Account Penalty Relief For U.S. taxpayers who did not previously report all of their foreign accounts, assets, investments, and income on their tax returns and other international information reporting forms, the Internal Revenue Service offers many different offshore disclosure programs and procedures they […]
6 Key Things You Must Know For IRS Form 5471 While it would appear that there are an infinite number of international information reporting forms required for taxpayers with overseas accounts and assets, Form 5471 is one of the more common and complicated forms. That is […]
An Overview of IRS Non-Willfulness Certification The Streamlined Offshore Procedures is a program developed by the IRS to allow non-willful Taxpayers to safely disclose their previously unreported foreign accounts, assets, investments, and income. When it comes to submitting to the Streamlined Domestic Offshore Procedures or […]
Can IRS Voluntary Disclosure Limit Criminal Tax Prosecution Risks? In the world of IRS Voluntary Disclosure, it is well-established that the VDP ‘Program’ is a good option for U.S. Taxpayers who may have committed a criminal tax violation, because the programs can minimize the risk of […]
Do You Bank with Banque Pictet et Cie Sa as a U.S. Person? Continuing the trend established by several Swiss banks before them, Banque Pictet has entered into a deferred prosecution agreement with the United States to minimize the damage of criminal misconduct aimed at assisting […]