Foreign Accounts Compliance Blog

Forms 8938, 5471, 3520 3520-A, 5472, 8865, and 926 and Assessable vs. Nonassessable Penalties

In the recent case of Farhy v. Commissioner, the Internal Revenue Service assessed penalties against Alon Farhy for failing to ...
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Required Minimum Distributions

Internal Revenue Code (“IRC”) Section 403(b) annuities, Section 401(k) plans, and Section 408 individual retirement arrangements, whether individual retirement accounts ...
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Supreme Court Signals Reversal in Bittner

On November 2 the Supreme Court held oral arguments in Bittner,[1] on whether the failure to timely file a Financial ...
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Supreme Court Grants Certiorari in Bittner

In United States v. Bittner, the U.S. Court of Appeals for the Fifth Circuit held that the $10,000 penalty for ...
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Michigan Durable Powers Of Attorney

If an individual (“principal”) while mentally competent executes a durable power of attorney, then his agent (also-called “attorney-in-fact”) acting under ...
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Expatriation From The United States

Renunciation of United States citizenship or abandonment of United States lawful permanent resident (“green card”) status is a major event ...
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United States Income Taxation Of United Kingdom-Based Pension Plans

Many United Kingdom citizens retire in the United States after working in the United Kingdom.  Such individuals’ interests in United ...
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Foreign Accounts Compliance Update

Immigration to the United States continues at a strong pace.  The people coming over tend to be members of the ...
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Internal Revenue Code § 965 and the Streamlined Procedures

Internal Revenue Code § 965, as added by the Tax Cut and Jobs Act of 2017, requires a controlled foreign ...
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Advantageous Abandonment of a U.S. Green Card

If you have the status of lawful permanent resident of the United States (i.e., you are a “green card” holder), ...
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