Foreign Accounts Compliance Blog

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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You May Only Need to File Delinquent FBARs

Many U.S. persons are alarmed upon learning of their reporting obligations with respect to foreign financial accounts.  Those obligations include ...
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Beneficial Ownership, Income Tax, and FBARs

For U.S. income tax purposes, ownership of property means beneficial ownership.  Only the beneficial owner of property is required to ...
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U.S. Persons’ Reporting Obligations Regarding Foreign Financial Assets

The United States imposes reporting obligations upon U.S. persons with respect to their worldwide income and financial assets.  The reporting ...
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Passive Foreign Investment Companies: U.S. Clients Should Consider Tax Compliance

Foreign mutual funds, known as passive foreign investment companies or “PFICs,” pose significant compliance burdens for U.S. taxpayers.  Click here for the ...
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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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Beneficial Ownership of a Foreign Financial Account

Beneficial ownership is a pivotal yet elusive concept in the foreign financial accounts arena.  Click here for the full article. Other posts ...
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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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