Farhy v. Commissioner In a recent landmark ruling, Farhy v. Commissioner, the Tax Court has significantly changed penalty assessments under I.R.C. Section 6038(b) of the Internal Revenue Code. This ruling, rendered on April 3, 2023, carries significant implications for a broad range of taxpayers, potentially offering a basis to challenge or request refunds for penalties
International Tax Reporting Requirements
Supreme Court Resolves FBAR Penalty Dispute: Per-Report Basis Confirmed
Introduction to the FBAR Penalty Dispute: In a significant decision, the U.S. Supreme Court recently ruled the penalty for violating the “Report of Foreign Bank and Financial Accounts” (FBAR) rules applies on a per-report basis, rather than a per-account basis. This decision brings clarity to a previously divided area of law, as the Fifth Circuit
FBAR – Foreign Bank Accounts Require Disclosure
FBAR – Foreign Bank Accounts Require Disclosure If you are U.S. Citizen or a Green Card holder and you have a bank account outside the United States, your foreign bank account(s) requires disclosure to the Internal Revenue Service (IRS) and the Financial Crimes Enforcement Network (FinCEN) through Form FinCEN 114 or FBAR. Every U.S. Citizen
Tax Treaty Provisions Are an Important Part of International Tax Reporting File IRS Form 8833 to Avoid Penalties!
What is a Tax Treaty? A tax treaty is an agreement between two countries intended to address and resolve issues such as double taxation of income for each country’s citizens or residents. The United States has tax treaties in place with numerous countries. These treaties seek to provide reciprocal reduced tax rates or exemptions for
International Tax Law for Non-Profits
International Tax Law In today’s economic climate non-profit organizations are looking globally to support continuing operations. However, in doing so, non-profits need to understand applicable international tax law and ensure compliance with applicable federal tax laws and IRS guidelines. This is especially important in cities like San Diego where non-profits may have operations in both
Internal Revenue Service Form 8938
An Important International Tax Form to Declare Foreign Financial Assets May be filed through the IRS Streamlined Procedures What is it Internal Revenue Form 8938? Form 8938 is used to report specified foreign financial assets when the overall value of the those specified foreign financial assets is over the appropriate reporting thresholds. The form requires
Complying with International Tax Reporting Requirements – Streamlined Procedures May Help
Streamlined Procedures – What Is It and Who Does It Assist? Streamlined Procedures may provide non-tax-compliant US citizens a remedy when the conduct was non-willful. The Streamline includes procedures and terms for filing amended or delinquent returns and for resolving open tax and penalty obligations. Part of the process includes filing three years of income