Category: Foreign Accounts Compliance

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...

At the American Bar Association Taxation Section’s annual meeting in Washington, D.C., in May, 2019, IRS representatives said the IRS continues examining evidence of Americans’ foreign financial accounts,...

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...

The United States taxes its citizens and residents on their worldwide income.  To evade U.S. income tax, U.S. taxpayers were transferring their funds to foreign financial institutions, which...

The United States taxes its citizens and residents on their worldwide income.  The Internal Revenue Service requires the filing of a series of information returns by U.S. taxpayers...

A U.S. taxpayer whose interest in a closely-held foreign corporation meets a specified threshold must file Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign...

The Internal Revenue Service recently announced that it is closing its Offshore Voluntary Disclosure Program, effective September 28, 2018. This is a positive development. Proceeding under the OVDP...

U.S. persons are required to report to the United States government concerning foreign financial accounts. A “U.S. person” is a citizen or resident of the United States. A...

Accountants commonly send an “organizer” to a client with instructions to complete and sign it and return it to the accountant.  The completed organizer then serves as the...

MnaBy Stephen J. Dunn Tax evasion is the most serious charge in the recent Indictment of Paul J. Manafort, Jr. and Richard W. Gates III. The Indictment avers...

FBARs If the total balance of your foreign financial accounts exceeds $10,000 at any time during a calendar year, then you must file an “FBAR” (the actual name...

The Internal Revenue Service’s Offshore Voluntary Disclosure Program (“OVDP”) is the most costly and administratively burdensome means of complying with U.S. laws concerning foreign financial accounts.  Very few...

We place clients into compliance with United States laws concerning foreign financial accounts with the least possible work and expense. In a typical case, a taxpayer or taxpayer’s...

U.S. persons are subject to compliance obligations concerning foreign financial accounts under two statutes, the Internal Revenue Code and the Bank Secrecy Act. A prior article explores who...

U.S.-based mutual funds annually issue to each of their shareholders a Form 1099 reporting the shareholder’s share of interest, dividends, and capital gains realized by the mutual fund...

For U.S. income tax purposes, ownership of property means beneficial ownership.  Only the beneficial owner of property is required to report taxable income from the property on a...

Many U.S. persons are alarmed upon learning of their reporting obligations with respect to foreign financial accounts.  Those obligations include reporting the accounts and income therefrom on U.S....

The United States imposes reporting obligations upon U.S. persons with respect to their worldwide income and financial assets.  The reporting obligations include reporting worldwide income on an annual...

             We assist persons in complying with U.S. laws concerning foreign financial accounts. We prepare FinCEN Forms 114 (formerly Form TD F 90-22.1), Report of Foreign Bank and...

          There are millions of individuals of Indian descent living in the United States.  Many of them left financial assets in India upon immigrating to...

Competent counsel should represent U.S. taxpayers who have failed to file FBARs reporting foreign financial accounts, or who have failed to report foreign financial assets or income therefrom...

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. Other posts of interest:...

Beneficial ownership is a pivotal yet elusive concept in the foreign financial accounts arena.  Click here for the full article. Other posts of interest: U.S. Persons' Reporting Obligations...

John Doe summonses are an expeditious weapon available to the U.S. government in identifying U.S. taxpayers' foreign financial accounts.  Click here for the full text. Other posts of...

Tax treaties, intergovernmental information exchange agreements, and the dilution of Swiss banking secrecy laws enable the U.S. government to identify U.S. taxpayers' foreign financial accounts.  Click here for...