News & Analysis as of November 15, 2024

Foreign Bank Accounts

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen

Allen Barron, Inc. on 7/19/2024

In US Expatriate Tax Planning – Part 2, Ms. Allen picks up the conversation regarding tax and legal issue U.S. expatriates might face. The discussion turns to real estate matters, and the issue of moving money from the United...more

Unreported Foreign Accounts? How to Choose the "Right" International Tax Attorney to Help You

Freeman Law on 2/24/2023

If you have unreported foreign accounts, you are not alone. Every year, I speak with hundreds of clients with tax non-reporting issues (e.g., FBARs, Form 8938, Form 3520, Form 3520-A, etc.). The good news: the IRS offers...more

What 2022 Has Taught Us About FBAR Willfulness

Freeman Law on 10/7/2022

The Bank Secrecy Act requires certain taxpayers to submit timely FBARs to the United States reporting their interests in foreign accounts. If a taxpayer has an FBAR filing requirement and misses it, the taxpayer can be...more

IRS Issues FBAR Reference Guide

Freeman Law on 4/11/2022

The IRS and FBARs - On March 30, 2022, the IRS issued Publication 5569, Report of Foreign Bank & Financial Accounts (FBAR) Reference Guide. The 12-page publication provides helpful information to both taxpayers and tax...more

The Evolving Standard of “Willfulness” in FBAR Cases: Where are We Now?

Freeman Law on 2/14/2022

The concept of “willfulness” is an important one in the FBAR civil penalty context. Indeed, a taxpayer’s willful failure to file a timely and accurate FBAR may result in significant penalties: the higher of 50-percent of...more

Criminal Tax Statutes of Limitations and Suspensions: 18 U.S.C. § 3292 and the Fifth Circuit’s Decision in Pursley

Freeman Law on 2/8/2022

In civil and in criminal cases, the Government must generally act within a certain prescribed time to take action against taxpayers. In legal parlance, this period of time is known as the “statute of limitations.” The...more

Non-Willful FBAR Penalties Will be Much Higher in the Fifth Circuit

Gray Reed on 12/1/2021

On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account...more

FBAR Penalties: Another Court Holds that FBAR Penalties Can Exceed the Regulatory Ceiling

Freeman Law on 8/6/2021

The Report of Foreign Bank and Financial Accounts (i.e., the “FBAR”) was for many years confined to the lonely backwaters of Title 31 of the United States Code—the intriguingly-named Bank Secrecy Act. For years, compliance...more

The FBAR (Report of Foreign Bank and Financial Accounts): Everything You Need to Know

Freeman Law on 7/26/2021

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

Closing A Foreign Bank Account Will Not Solve A Taxpayer’s Disclosure Problem

Foodman CPAs & Advisors on 4/22/2021

IRS is interested in U.S. Taxpayer financial accounts everywhere in the world. If the IRS learns that a Taxpayer has undisclosed reportable accounts or income before a US Taxpayer reports them, the Taxpayer can face serious...more

19 Possible Questions That Your Tax Preparer Ought to Ask Regarding Foreign Accounts and Assets

Foodman CPAs & Advisors on 4/15/2021

Many Taxpayers with international entanglements seek the assistance of tax return preparers without U.S. international tax reporting experience. Because US International tax reporting is complicated and often overwhelming...more

Death Doesn’t Stop the IRS—Failure to File FBARs

Freeman Law on 12/17/2020

Benjamin Franklin once famously wrote in a 1789 letter, “In this world nothing can be said to be certain, except death and taxes.” Many recognize the truth in Mr. Franklin’s statement. Some may also believe that certain death...more

FBAR Penalties: Is it per Account or per Violation?

Foodman CPAs & Advisors on 2/7/2020

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

IRS gives Internal Revenue Manual Voluntary Disclosure Consideration if…….

Foodman CPAs & Advisors on 10/12/2018

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

Avoid this while filing your taxes

Foodman CPAs & Advisors on 4/13/2018

To avoid possible scrutiny or oversight by the IRS, Accuracy is a key factor when filing Tax Returns. Taxpayers want to make sure that their returns are processed correctly by the IRS. ...more

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Income Taxes › Tax Planning › Foreign Bank Accounts

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