Foreign mutual funds, known as passive foreign investment companies or “PFICs,” pose significant compliance burdens for U.S. taxpayers. Click here for the full article.
The first thing a taxpayer should do who is out of compliance with United States laws concerning foreign financial accounts is immediately file delinquent FinCEN Forms 114, Report of Foreign Bank and Financial Accounts, (“FBARs”), or amended FBARs for the preceding six years. The statute of limitations on assessment of penalties for failure to file an FBAR is six years, and it begins to run when the FBAR is due,...
Under the Bank Secrecy Act, a U.S. person with foreign account balances aggregating more than $10,000 at any time during a calendar year must file a FinCEN Form 114, Report of Foreign Bank and Financial Accounts, (“FBAR”), for that year. A U.S. person is subject to a $10,000 penalty for failure to file an FBAR. If the failure is determined to be “willful,” the penalty is the greater of 50%...
