Category: Paths to 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...

The Internal Revenue Service ended its Offshore Voluntary Disclosure Program (“OVDP”) effective September 28, 2018. Since then the IRS has made its Voluntary Disclosure Practice (“VDP”) available to...

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...

Many Americans become compliant with U.S. laws concerning foreign financial accounts by means of the Streamlined Filing Compliance Procedures (the “Streamlined Procedures”). To qualify for the Streamlined Procedures,...

A U.S. taxpayer whose interest in a foreign partnership meets a specified threshold must file with his U.S. income tax return Form 8865, Return of U.S. Persons With...

The United States taxes its citizens and residents on their worldwide income.  Accordingly, the U.S. Internal Revenue Code requires U.S. taxpayers whose interests in foreign financial accounts exceed...

The United States taxes its citizens and residents on their worldwide income.  To ascertain U.S. taxpayers’ foreign income, the Internal Revenue Service requires the filing of a series...

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...

Recently, a man called who had first called me in 2015.  When he first called, the man wanted to become compliant with U.S. laws concerning foreign financial accounts. ...

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...

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...

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...

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. ...

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...