Foreign Accounts Compliance Blog

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

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

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

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

Renunciation of United States citizenship or abandonment of United States lawful permanent resident (“green card”) status is a major event ...

Many United Kingdom citizens retire in the United States after working in the United Kingdom.  Such individuals’ interests in United ...

Immigration to the United States continues at a strong pace.  The people coming over tend to be members of the ...

Internal Revenue Code § 965, as added by the Tax Cut and Jobs Act of 2017, requires a controlled foreign ...

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

The United States taxes its citizens and residents (“U.S. persons”) on their worldwide income.  U.S. persons commonly used foreign financial ...