Many US taxpayers still have questions regarding offshore accounts and FBAR filing requirements and compliance. Is there a genuine risk their activities (or lack of compliance) will come to light? The definition of a US...more
When is a US Taxpayer required to disclose offshore accounts on an FBAR and IRS Form 8938? While many US taxpayers and expatriates have come to understand the requirements of the FinCEN Form 114 or FBAR, a surprising number...more
It is common for a US taxpayer to ask “what happens if you don’t file an FBAR or a Form 8938, Statement of Specified Foreign Assets with the IRS? Why do I have to worry about filing an FBAR in San Diego or anywhere in the US,...more
Every year, the IRS compiles a list of common scams that taxpayers may encounter – its so-called “Dirty Dozen.” Today, the Service wrapped up the annual Dirty Dozen list of tax scams for 2023 with a reminder for taxpayers,...more
Después de una investigación de un año, el Comité de Finanzas del Senado de los EE. UU. investigó una escapatoria (FATCA Loophole) y entregó un Reporte de investigación titulado “The Shell Bank Loophole” que expone un esquema...more
According to the IRS, the Dirty Dozen represents the worst of the worst tax scams. The Dirty Dozen is a list that is compiled annually by the IRS in order to alert taxpayers, tax professionals and financial institutions of...more
The IRS wrapped its 2022 Dirty Dozen scams list urging taxpayers to watch out for and avoid being misled by tax avoidance strategies. Making the 2022 List are Cryptocurrency, non-filing, abusive syndicated conservation...more
El Informe de TIGTA (“Treasury Inspector General for Tax Administration”) del 7 de abril de 2022 detalla seis recomendaciones de acciones adicionales necesarias para abordar el cumplimiento de la falta de presentación y...more
The TIGTA Report dated April 7, 2022 details six recommendations for additional actions needed to address Non-Filing and Non-Reporting Compliance Under FATCA. ...more
Since 2017, the Internal Revenue Service (IRS) Large Business and International Division (LB&I) has shifted its audit efforts to issue-based examinations, premised on strategically identified and prioritized areas of...more
On July 29, 2021, the United States Attorney for the Southern District of New York, the Assistant Attorney General for the Department of Justice Tax Division, and the IRS Commissioner all announced that a federal court in New...more
The 2022 discretionary funding request (request) made by the Biden Administration will invest in a “fair and robust” tax system that includes tax compliance enforcement directed at High Income and High Net Worth Individuals...more
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 Large Business and International (IRS LBI) currently has 59 Active Compliance Campaigns. The purpose of the IRS compliance campaign strategy is to redefine large business compliance work and build a supportive...more
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
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
On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced three new compliance campaigns. The campaigns focus on: ..Transfer pricing for “captive” services...more
The Internal Revenue Service (IRS) Large Business and International (LB&I) Division continues to churn out new audit “campaigns.” For our prior coverage... The most recent set of campaigns were announced on April 16, 2019,...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
Today the IRS published a reminder to foreign financial institutions and their compliance officers that certifications required by the Foreign Account Tax Compliance Act (FATCA) are due no later than December 15, 2018. This...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
In recent months, the Internal Revenue Service (“the Service”) began the process of issuing follow-up letters to taxpayers who either requested preclearance to participate in the Offshore Voluntary Disclosure Program (“OVDP”)...more
The Internal Revenue Service has issued its annual reminder to taxpayers that they report their foreign assets on their individual tax returns due on April 17, 2018. Individuals with offshore assets such as bank accounts...more
The IRS recently announced it will be shutting down its successful Offshore Voluntary Disclosure Program (OVDP) for unreported foreign bank accounts and income. The program will end September 28, 2018. Under the OVDP, first...more