What do you need to know about the IRS updated Streamlined Filing Compliance Procedures or "Streamlined Procedures?" Are you concerned about unreported or under-reported offshore income or assets? Are there accounts you...more
What are the most important elements of estate and tax planning for US expatriates? Are you planning to move out of the United States? Are you a US taxpayer who lives and works outside of the country? What are some of the...more
On February 28, 2023, in a significant tax case, Bittner v. US, the U.S. Supreme Court held that a U.S. person who fails to file his or her FBAR on a non-willful basis only is subject to a single penalty on the failure to...more
Increasing demand for transparency and tax rules focused on the ownership of foreign financial accounts and interests in foreign trusts and entities affect private wealth planning. There are steps you can take to comply with...more
Missing any deadline is stressful. But missing a tax deadline is more so. Per the Bank Secrecy Act (Title 31 of the U.S. Code), certain taxpayers must file so-called FBARs (currently FinCEN Form 114) with the government...more
Federal case and after federal case continues to come out providing real-life examples of the pitfalls of filing a Streamlined Filing Compliance Procedure (“SFCP”) with the IRS when the facts suggest willfulness rather than...more
Certain individuals who have only signature authority over non-US financial accounts now have until April 15, 2023 to file the Report of Foreign Bank and Financial Accounts....more
FinCEN has issued a notice that it intends to amend the regulations implementing the Bank Secrecy Act (BSA) regarding reports of foreign financial accounts (FBAR) to include virtual currency as a type of reportable account...more
Certain individuals who have only signature authority over foreign financial accounts now have until April 15, 2022 to file the Report of Foreign Bank and Financial Accounts. On December 9, 2020, the US Department of the...more
Individuals who own virtual currency should consult with a tax professional to determine if their virtual currency is subject to a reporting requirement. On December 31, 2020, the Financial Crimes Enforcement Network...more
On December 9, 2020, the Financial Crimes Enforcement Network (“FinCEN”) issued Notice 2020-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain...more
What is the Report of Foreign Bank and Financial Accounts (FBAR)? Congress enacted the statutory basis for the requirement to report foreign bank and financial accounts in 1970 as part of the “Currency and Foreign...more
On December 20, 2019, the Financial Crimes Enforcement Network (“FinCEN”) issued Notice 2019-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain...more
On December 4, 2018, FinCEN issued Notice 2018-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain individuals with signature or other authority over...more
Certain individuals who have only signature authority over foreign financial accounts now have until April 15, 2020, to file the Report of Foreign Bank and Financial Accounts....more
On November 29, 2018, the Internal Revenue Service (the "IRS") published a memorandum (the "Memorandum") dated November 20, 2018, outlining the new process for all voluntary disclosures, both domestic and offshore (the "New...more
On December 4, 2018, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced a further extension of time for Report of Foreign Bank and Financial Accounts (FBAR) filings for certain individuals with...more
There are legal and financial consequences to any U.S. person who underreports their income. Moreover, similar consequences may exist even in a situation in which all income is reported, yet certain information returns are...more
On March 13th, the Internal Revenue Service ("IRS") announced that the offshore voluntary disclosure program ("OVDP"), which was first launched in 2009 and modified several times, will close to new taxpayers after September...more
Investment advisers registered with the U.S. Securities and Exchange Commission (“SEC”) or with a state (“Advisers”) as well as commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) registered with the...more
Certain individuals who have only signature authority over foreign financial accounts now have until April 15, 2019 to file the Report of Foreign Bank and Financial Accounts....more
Last week the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) again extended the deadline for certain financial professionals to file foreign bank accounting reporting forms known as FBARs. In FinCEN...more
On December 16, 2016, FinCEN issued Notice 2016-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain individuals with signature or other authority over...more
Certain individuals who have only signature authority over foreign financial accounts now have until April 15, 2018 to file the Report of Foreign Bank and Financial Accounts....more
Every U.S. person (including both individuals and entities, as discussed below) that had a financial interest in, or signature or other authority over, one or more foreign financial accounts during 2015 must electronically...more