U.S. Taxpayers (includes a citizen, permanent resident, corporation, partnership, limited liability company, trust and estate) are required to file a Report of Foreign Bank and Financial Accounts (FBAR) if they have...more
2/7/2020
/ FBAR ,
FinCEN ,
Foreign Bank Accounts ,
Income Taxes ,
IRS ,
Offshore Banks ,
Offshore Funds ,
Reporting Requirements ,
Tax Court ,
Tax Evasion ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Tax Returns
An individual that provides information to an attorney may normally assume that the information provided to the attorney will be kept confidential under the attorney-client privilege. That said, according to the Internal...more
On June 7, 2019, the Organisation for Economic Co-operation and Development (OECD) released a Memo which is a “summary of ongoing work to assess the impact of increasing tax transparency and exchange of information (EOI) on...more
10/4/2019
/ Bank Deposits ,
Common Reporting Standard (CRS) ,
Cross-Border Transactions ,
Data Management ,
Exchange of Information ,
FATCA ,
International Financial Reporting Standards ,
OECD ,
Offshore Funds ,
Tax Evasion ,
Tax Revenues ,
Transparency
On June 20, 2019, the National Taxpayer Advocate (TA), an independent organization within the IRS that helps taxpayers and protects taxpayer rights, issued a final Report to Congress. A section of the report focused on the...more
9/27/2019
/ Amended Rules ,
Burden of Proof ,
Criminal Liability ,
Criminal Penalties ,
FBAR ,
Foreign Assets ,
IRS ,
Offshore Funds ,
OVDP ,
Reporting Requirements ,
Voluntary Disclosure
The IRS produces a yearly list of Tax Scams known as the Dirty Dozen that Taxpayers may encounter. IRS reiterates that Tax Scams put Taxpayers at Risk when it releases its list of Dirty Dozen Tax Scams. These aggressive...more
7/8/2019
/ Charitable Deductions ,
Failure to Report ,
False Documentation ,
FATCA ,
Identity Theft ,
IRS ,
Offshore Funds ,
Phishing Scams ,
Qualified Disaster Relief Payments ,
Risk Mitigation ,
Tax Credits ,
Tax Deductions ,
Tax Penalties ,
Tax Preparers ,
Tax Scams ,
Tax Shelters ,
Unsolicited Phone Calls
El 15 de marzo del 2019, el IRS informó que la ocultación de dinero o activos en cuentas extraterritoriales (“offshore”) no declaradas permanece en la lista de las estafas tributarias conocidas come la Docena Sucia o "Dirty...more
5/13/2019
/ FATCA ,
FBAR ,
Filing Requirements ,
Foreign Bank Accounts ,
IGAs ,
Income Taxes ,
IRS ,
Offshore Banks ,
Offshore Funds ,
OVDP ,
Tax Evasion ,
Tax Liability ,
Tax Returns ,
Tax Scams
On March 15, 2019, IRS reported that hiding money or assets in unreported offshore accounts remains on the Internal Revenue Service’s “Dirty Dozen” list of tax scams for 2019....more
5/13/2019
/ FATCA ,
FBAR ,
Filing Requirements ,
Foreign Bank Accounts ,
IGAs ,
Income Taxes ,
IRS ,
Offshore Banks ,
Offshore Funds ,
OVDP ,
Tax Evasion ,
Tax Liability ,
Tax Returns ,
Tax Scams
IRS holds information that is sourced from the FATCA reports submitted by Foreign Financial Institutions (FFI) (on Form 8966 - FATCA Report) and by Individual US Taxpayers that have reporting obligations via Form 8938...more
4/1/2019
/ Banking Sector ,
FATCA ,
Foreign Financial Accounts ,
Global Intermediary Identification Number (GIIN) ,
IRS ,
Offshore Funds ,
Reporting Requirements ,
Tax Evasion ,
Tax Planning ,
Threshold Requirements ,
Voluntary Disclosure
After the closing of the Offshore Voluntary Disclosure Program (OVDP) - which ended on September 28, 2018, the US Department of Treasury released a Memorandum on November 20, 2018, disclosing an “Updated Voluntary Disclosure...more
On September 28, 2018, the IRS closed the Offshore Voluntary Disclosure Program (2014 OVDP). The 2014 OVDP (and prior 2011 and 2009 programs) had the purpose of providing Taxpayers that WILLFULLY failed to report foreign...more
The Responsible Officer (RO) of a Participating Foreign Financial Institution (PFFI) or Reporting Model 2 FFI is required to file the FFI’s FATCA certification of an Entity’s preexisting accounts (COPA) and its Periodic...more
The days of avoiding taxes through hiding money or assets in unreported offshore accounts are gone. Nonetheless, there are still taxpayers with undeclared offshore accounts, as well as the banks and bankers that are...more
On January 31, 2017, the IRS Large Business and International Division (LBI) announced a compliance campaign strategy to redefine large business compliance work and build a supportive infrastructure inside the LBI. ...more
12/10/2018
/ Audits ,
Cooperative Compliance Regime ,
Corporate Taxes ,
Economic Development ,
Foreign Earned Income ,
Foreign Tax Credits ,
Internal Revenue Code (IRC) ,
IRS ,
Large Business & International Division (LB&I) ,
Offshore Funds ,
S-Corporation ,
Swiss Banks ,
Tax Planning ,
TEFRA ,
Transition Tax ,
Virtual Currency
El 11 de Noviembre del 2018, el Departamento de Justicia de los EE. UU. (“DOJ”) informó que el banquero Adrian Baron, el ex Director de Negocios y ex Director Ejecutivo de Loyal Bank Ltd, un banco “off-shore” con oficinas en...more
11/2/2018
/ Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Failure to Comply ,
FATCA ,
Financial Services Industry ,
Foreign Financial Institutions (FFI) ,
IGAs ,
IRS ,
Offshore Funds ,
Reporting Requirements ,
Strict Compliance ,
Tax Evasion ,
Tax Planning
On September 11, 2018, the US Department of Justice (DOJ) reported that banker Adrian Baron, the former Chief Business Officer and former Chief Executive Officer of Loyal Bank Ltd, an off-shore bank with offices in Budapest,...more
11/2/2018
/ Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Failure to Comply ,
FATCA ,
Financial Services Industry ,
Foreign Financial Institutions (FFI) ,
IGAs ,
IRS ,
Offshore Funds ,
Reporting Requirements ,
Strict Compliance ,
Tax Evasion ,
Tax Planning
When IRS reviews a criminal tax case, consideration is given to various factors such as whether a voluntary disclosure was made, whether prosecution exists, the health, age and mental condition of the Taxpayer and whether a...more
Una certificación FATCA consiste en respuestas a una o más serie de preguntas que los Oficiales Responsables (RO) de ciertas entidades deben responder y enviar al IRS para confirmar el cumplimiento de las entidades con los...more
A FATCA certification consists of answers to one or more series of questions that the Responsible Officers (RO) of certain entities must answer and submit to the IRS to confirm the entities’ compliance with the requirements...more
Both the American Bar Association (ABA) and the American Institute of Certified Public Accountants (AICPA) have written letters (3/19/18 for the ABA and 5/30/18 for the AICPA) to the IRS to obtain further definition and...more
9/24/2018
/ Bitcoin ,
Cryptocurrency ,
Digital Currency ,
FBAR ,
Foreign Exchanges ,
Foreign Financial Accounts ,
Foreign Financial Institutions (FFI) ,
IRS ,
Offshore Funds ,
Reporting Requirements ,
Tax Evasion ,
Tax Planning ,
Virtual Currency
The jurors in the Paul Manafort case had questions regarding the complex Foreign Bank Account Reports (FBARs) regulations. This was evidenced by the jury’s questions to the judge addressing the responsibility to file an FBAR...more
On March 13, 2018, IRS announced the termination of the Offshore Voluntary Disclosure Program (OVDP) as of September 28, 2018 (Notice IR-2018-52). ...more
El 5 de Julio del 2018, el Inspector General del Tesoro para la Administración Tributaria (TIGTA) emitió un informe: https://www.treasury.gov/tigta/auditreports/2018reports/201830040fr.pdf titulado: "A pesar de gastar casi...more
On July 5, 2018, the Treasury Inspector General for Tax Administration (TIGTA) issued a report https://www.treasury.gov/tigta/auditreports/2018reports/201830040fr.pdf titled: “Despite Spending Nearly $380 Million, the...more
Tax Reform came and went and FATCA is still standing. While U.S. Corporations are now moving to a Territorial tax system, Individual U.S. Taxpayers living abroad ARE STILL REQUIRED to REPORT their worldwide income.
...more
On April 9, 2018, IRS released Notice (IR-2018-87) to remind Taxpayers that hold foreign assets of their U.S. tax obligations which could include a filing requirement and a U.S. tax liability. This Notice applies to all U.S....more
4/13/2018
/ Banking Sector ,
FATCA ,
FBAR ,
Foreign Financial Accounts ,
IRS ,
Offshore Funds ,
OVDP ,
Reporting Requirements ,
Tax Evasion ,
Tax Planning ,
Voluntary Disclosure