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
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
Delinquent Report of Foreign Bank Accounts – (FBAR) Submission Procedures
Foreign Bank Accounts If you have a foreign bank account that had a balance of at least $10,000 at any point during the calendar year, federal law requires you disclose the existence of such an account to the Internal Revenue Service. A taxpayer must file a Report of Foreign Bank and Financial Accounts (known as
Should You Hire a Tax Attorney?
Should You Hire a Tax Attorney? It’s the kind of mail nobody wants to receive—a letter from the IRS. It’s pretty much given that any mail you get from the agency is most likely not going to contain good news. If you receive a letter from the IRS you have an important decision to make.
IRS FBAR Requirements Part 2
To read part 1 of this post, click here. Offshore Voluntary Disclosure Program The IRS reopened the Offshore Voluntary Disclosure Program (OVDP) in 2012 after taxpayers continued to express interest after the closure of the program in 2009 and 2011. The Offshore Voluntary Disclosure Program, also known as the Offshore Voluntary Disclosure Initiative, gives taxpayers
FBAR Requirements
Do you need to file a Foreign Bank Account Report (FBAR)?Taxes are confusing, and international tax laws are even more complex. The IRS has been working diligently to create a better system to bring offshore accounts into compliance, and one way they have done this is through FBAR requirements including Offshore Voluntary Disclosure Program (OVDP)/Offshore
IRS OVDI – Role of the Attorney in the Voluntary Disclosure Process
Role of the Attorney in the Voluntary Disclosure Process An attorney that specializes in taxes can be a great resource to those who are seeking to rectify the non-disclosure status of any foreign accounts and/or income. Although participation in the Voluntary Disclosure program reduces the likelihood that the IRS will pursue further civil and criminal
Quiet v. Voluntary Disclosure
IRS OVDI – Quiet v. Voluntary Disclosure In some cases, a taxpayer who has previously unreported foreign income may decide to amend their tax returns in order to avoid some of the harsh penalties involved with non-disclosure rules. They also pay any past due penalties and interest that has accrued based on this new unreported
What to Do if You Have an Undeclared Foreign Bank Account
IRS OVDI – I have an undeclared foreign bank account. What do I do? Ownership of an undeclared foreign bank account can cause the average American taxpayer to feel a sense of impending doom. Due to the many disclosure laws that have been implemented over the years, and the potential fines and criminal penalties they
IRS OVDI – Foreign Income and Foreign Bank Accounts Reporting Requirements
IRS OVDI Due to the globalization of the world’s economy over the last few decades, many Americans are receiving an ever increasing amount of income from foreign sources. Some of this income is held in oversea banks and other financial institutions. However, due to both the use of foreign financial transactions in funding terrorism, and