By Sebastien Chain and Tamara Woods Beginning with the 2011 tax year (i.e., for returns filed April 17, 2012 or later), individual taxpayers will be required to file Form 8938 if he or she has an interest in a “specified foreign financial asset” (“SFFA”) (click for additional information on FATCA requirements) that has a value exceeding a certain threshold. [...]
Posted tagged ‘FBAR’
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Form 8938 – Foreign Reporting Trap for the Unwary
April 11, 2012Categories: Individual, International
Tags: FBAR, Foreign Assets, Form 8938, International
Comments: 1 Comment
More Foreign Reporting for US Taxpayers? Absolutely says IRS
April 3, 2012By Sebastien Chain and Tamara Woods The Hiring Incentives to Restore Employment Act of 2010 (“HIRE Act”) enacted the Foreign Account Tax Compliance Act (“FATCA”). P.L. 111-47. FATCA greatly increases disclosure requirements and penalties on taxpayers with foreign accounts and assets. These reporting requirements will affect individuals beginning with the 2011 tax year, and are expected [...]
Categories: Individual, International
Tags: FBAR, Foreign Assets, Form 8938, International
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Sporadic FBAR Notices Should Be Replaced By Clear Rules
February 27, 2012By: Dustin Covello On February 14, the Financial Crimes Enforcement Network (FINCEN) issued Notice 2012-1, which extends the 2011 and 2012 FBAR filing deadline for certain individuals to June 30, 2013. The notice extends relief previously granted by FINCEN to employees and officers with signature authority over bank accounts owned by subsidiaries of certain regulated [...]
Categories: Administrative, International
Tags: FBAR, FinCEN, offshore bank accounts, OVDI
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When Bygones Aren’t Bygones: Exploring Tax Solutions for U.S. Persons with Undeclared Canadian Retirement Plans and Accounts
February 24, 2012By Hale Sheppard Many Canadians migrate south each year and become U.S. residents or citizens. Along with the cold weather, they may also leave behind local retirement account, such as a Canadian registered retirement savings plan (“RRSP”) or a Canadian registered retirement income fund (“RRIF”). Preserving this Canadian nest egg is generally a good thing. [...]
Categories: International
Tags: Canadian Accounts, FBAR, international tax, Private Letter Ruling Requests, Registered Retirement Plan, retirement income fund, RRIF, RRSP
Comments: 1 Comment
The Romneys’ Tax Returns: Have FBARs Been Filed, Or Is Romney An OVDI “Candidate”?
January 25, 2012By Jonathan Prokup and Dustin Covello Following the release of Ann and Mitt Romney’s tax returns, the news media and political commentators of all stripes have – to paraphrase Arlo Guthrie – detected, neglected, selected, rejected, and inspected those returns for a variety of commercial and political purposes. As expected, the return shows substantial income, [...]
Categories: Administrative, Individual, International
Tags: FBAR, foreign investment, Mitt Romney, offshore bank accounts, OVDI, Penalties, PFIC
Comments: 1 Comment
Fox Business Interview: OVDI, FBARs, And The Economic Benefits Of A Repatriation Holiday
January 17, 2012By Jonathan Prokup Fox Business invited me to appear yesterday on “After The Bell” with Liz Claman and David Asman to discuss (i) the IRS reopening the disclosure initiative for offshore bank accounts and (ii) the ongoing debate about whether Congress should implement a corporate repatriation holiday. A link to the video is below the [...]
Categories: Administrative, International
Tags: FBAR, IRS, job creation, offshore bank accounts, OVDI, repatriation, stimulus, Taxes
Comments: 1 Comment
IRS Reopens Offshore Voluntary Disclosure Initiative (OVDI) For Delinquent FBAR Filers: 27.5 Percent Penalty
January 10, 2012By Jonathan Prokup and Dustin Covello The IRS announced yesterday a reopening of its 2011 offshore voluntary disclosure initiative (“OVDI”). This program will have essentially the same terms as the 2011 OVDI, but with a penalty rate of 27.5 percent (rather than 25 percent) of the highest account balance during the period covered by the [...]
Categories: Administrative, Individual, International
Tags: Credit Suisse, FBAR, HSBC, offshoare bank accounts, OVDI, Penalties, Swiss, tax evasion
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Good News For Bank Account Disclosures By U.S. Citizens Residing In Canada
December 5, 2011By Jonathan Prokup Over the weekend, a variety of Canadian news sources (see, e.g., the Financial Post and the Edmonton Journal) reported on anticipated guidance from the IRS, which would result in the waiver of penalties on certain U.S. citizens living in Canada for past failures to file Form TD F 90-22.1, commonly known as [...]
Categories: Administrative, Individual, International
Tags: bank accounts, Canada, disclosure, FBAR, IRS, OVDI
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After OVDI: What’s Next For Disclosures Of Foreign Bank Accounts?
December 2, 2011By Jonathan Prokup For taxpayers who entered the IRS’s second Offshore Voluntary Disclosure Initiative (“OVDI”) prior to August 31, 2011, November 29th marked the end of the extended deadline that some taxpayers requested for submitting all of the materials included in the disclosure (e.g., amended returns, FBARs). Coincidentally with the timing of this deadline, many [...]
Categories: Administrative, Corporate, Individual, International
Tags: bank account, FBAR, IRS, noisy disclosure, OVDI, Penalties, quiet disclosure
Comments: 7 Comments
Going Quietly Into The Night May Not Be The Best Idea For U.S. Citizens Living Abroad
August 26, 2011Apparently, there are a large number of U.S. citizens living outside the United States as well as a large number of individuals who are dual citizens of the United States and their country of residence (estimated to be in the millions). Judging from the phone calls that I have been receiving from my contacts at foreign [...]
Categories: Administrative, International
Tags: FBAR, foreign bank accounts, OVDI, tax evasion
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Phil Karter
Jonathan Prokup
David Shakow
George Connelly, Jr.
Buck Buchanan
David Bernard
Dustin Covello
Heather Pesikoff
Hale Sheppard
dustincovello
