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.
FATCA
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.
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.
Transnational tax information reporting: A guide for the perplexed
This article alerts the practitioner to when an information return may be necessary.
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.
Hidden insurance excise tax obligations arising from corporate chargebacks
When group policies are purchased from foreign insurance companies, there may be federal insurance excise tax issues.
Developing a strategy to fight FBAR penalties
This article discusses the strategic considerations involved in mounting a defense to FBAR penalties based on a claim of a violation of the Administrative Procedure Act.
FinCEN Grants Permanent Automatic Extensions for FBARs
Starting this year, FBARs have a new, April 15 due date, with extensions to Oct. 15.
An Update on Foreign Financial Account Reporting
This article revisits the reporting requirements for an FBAR and highlights FBAR reporting requirements that differ from those of Form 8938.
Online Poker Accounts Not Subject to FBAR Reporting
The Ninth Circuit held that a taxpayer’s accounts with two foreign-based online poker sites were not bank accounts that a taxpayer must report on an FBAR.
IRS Revises Forms 1042-S and W-8BEN-E for 2016
The IRS issued 2016 versions of Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, and Form W-8BEN-E, Certificate of Status of Beneficial Owner for United States Tax Withholding and Reporting (Entities).
Are Problems Looming for FATCA and the “Reciprocal” IGA?
The Treasury Department may soon experience relationship problems with certain countries that have entered into intergovernmental agreements under FATCA.
Specified Domestic Entities Must Now Report Under Sec. 6038D
The regulations require specified domestic entities to report specified foreign financial assets in which they have interests.
Court Dismisses FATCA Challenges
In a case challenging the foreign reporting requirements under FATCA and the Report of Foreign Bank and Financial Accounts, a number of plaintiffs, including Sen. Rand Paul of Kentucky, had their claims dismissed by a federal court.
FATCA Deemed Stock Distribution Reporting Rules Proposed
The IRS issued proposed regulations providing guidance that clarifies the amount, timing, and reporting of deemed distributions of stock and rights to acquire stock.
The Common Reporting Standard: Impact on Financial Services Institutions
The CRS requires financial institutions resident in participating jurisdictions to implement due-diligence procedures, to document and identify reportable accounts, and to establish a wide-ranging reporting process.
