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...

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,...

The United States taxes its citizens and residents on their worldwide income.  The Internal Revenue Service requires U.S. taxpayers to file information returns concerning foreign assets, accounts, and...

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...

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...

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...

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. ...

The Tax Cut and Jobs Act (“TCJA”) just signed into law by President Trump sharply curtails your ability to claim itemized deductions after 2017.   So, you should try...

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...

The United States does not tax a parent corporation on the earnings of its subsidiary until the subsidiary distributes the earnings to the parent as a dividend.  This...

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...