Foreign Accounts Compliance

Compliance Required of U.S. Persons Concerning Foreign Financial Accounts

U.S. persons are subject to compliance obligations concerning foreign financial accounts under two statutes, the Internal Revenue Code and the ...
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Reporting Horrors of Foreign Mutual Funds (“PFICs”)

U.S.-based mutual funds annually issue to each of their shareholders a Form 1099 reporting the shareholder’s share of interest, dividends, ...
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Is It A Foreign Account?

The Bank Secrecy Act, 31 USC 5314, authorizes the U.S. Treasury to enact regulations concerning transactions by a United States ...
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The Use of John Doe Summonses in Identifying U.S. Persons’ Accounts

John Doe summonses are an expeditious weapon available to the U.S. government in identifying U.S. taxpayers’ foreign financial accounts.  Click here for ...
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