Supreme Court holds FBAR penalty is imposed per report, not per account
The Supreme Court held that the $10,000 maximum penalty for the nonwillful failure to file a compliant report applies on a per-report, not a per-account, basis.
FATCA Compliance & FBAR Reporting
US clients with international tax issues: Five helpful tips
U.S. persons (citizens and permanent residents) whose financial matters extend overseas may face a tax situation that virtually no other country’s nationals do.
Counsel’s admission costly to taxpayer in FBAR case
The Third Circuit affirmed a district court’s holding that a taxpayer’s failure to report his foreign accounts on FinCEN Forms 114, Report of Foreign Bank and Financial Accounts (FBAR), was willful.
Supreme Court to resolve FBAR penalty dispute
By agreeing to hear a Romanian-born businessperson’s appeal, the Supreme Court will address a circuit split over how to stack maximum penalties for multiple nonwillful civil violations for failure to file the FBAR.
IRS’s FATCA enforcement fell short, TIGTA says
Initial plans for the Foreign Account Tax Compliance Act’s regime of reporting US taxpayers’ foreign bank accounts and other financial assets largely have stalled, the Treasury Inspector General for Tax Administration reports.
Penalty for failure to report distribution from foreign trust not reduced
The penalty for failure to report a distribution from a foreign trust is not reduced when the trust beneficiary is also the trust owner.
Virtual currency update
Treasury takes a more aggressive stance on reporting of virtual currency transactions.
Foreign financial asset filing requirements: Coming into compliance
This article summarizes the options available to taxpayers to come into compliance with FBAR and information reporting obligations.
FBAR deadline extended to Oct. 31 after confusion
After a misworded posting caused confusion about the 2020 deadline to file FBARs (i.e., FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)), Treasury’s Financial Crimes Enforcement Network has extended the deadline to Oct. 31.
FinCEN pulls announcement of extended FBAR deadline
Treasury’s Financial Crimes Enforcement Network briefly announced, but then rescinded, an extension of this year’s deadline to e-file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).
Virtual currency not FBAR reportable (at least for now)
The AICPA Virtual Currency Task Force reached out to Treasury’s Financial Crimes Enforcement Network (FinCEN) to help practitioners answer the question of whether virtual currency (or cryptocurrency) must be reported on FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).
Offshore account holders should beware: The IRS is still coming
Taxpayers with undisclosed offshore accounts would be wise to take advantage of the lesser known IRS voluntary disclosure process.
Regulatory fatigue? FATCA inaction may risk noncompliance
Financial institutions need to remain vigilant and periodically update their compliance systems to ensure they remain fully compliant with the law.
Filing deadline for 2017 FBARs same as for individual tax returns
FinCEN issued its annual reminder of the due date for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts.
Transnational tax information reporting: A guide for the perplexed
This article alerts the practitioner to when an information return may be necessary.
External reviewer independence requirements and the 2017 QI Agreement
The IRS published a FATCA FAQ to establish a temporary standard of independence until it can provide comprehensive guidance.
FinCEN announces filing deadline for 2017 FBARs
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued its annual reminder of the due date for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).
Reporting foreign trust and estate distributions to U.S. beneficiaries: Part 2
Part 2 of this three-part series analyzes legal and beneficial ownership concepts as applied to a trust or estate created and administered in a foreign common law jurisdiction in contrast to a civil law jurisdiction.
Reporting foreign trust and estate distributions to U.S. beneficiaries: Part 1
Part 1 (of three) explains the classification criteria of a foreign nongrantor trust or foreign estate for U.S. tax purposes and the proper information reporting after U.S. taxes are withheld.
Recent developments under FATCA, U.S. withholding tax, and global information reporting
This item looks at ongoing IRS guidance.
