Category: FBARs

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...

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...

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...

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....

             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...

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...

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...

Congress enacted the FBAR filing obligation, and the draconian penalty for failure to discharge the obligation, to curb the use of foreign accounts to evade U.S. income tax. ...

The Bank Secrecy Act, 31 USC 5314, authorizes the U.S. Treasury to enact regulations concerning transactions by a United States person with a foreign financial agency.  A Regulation under the...

A client recently received a letter from a Swiss bank “strongly encouraging” the client to enter the Internal Revenue Service (“IRS”) Offshore Voluntary Disclosure Program (“OVDP”).  The letter...

There are two reasons for a taxpayer to enter the IRS’ Offshore Voluntary Disclosure Program (“OVDP”).  First, to avoid a criminal prosecution.  Second, to avoid the draconian civil...