Category: Delinquent International Information Return Submission Procedures

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...

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...

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...