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).
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.
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.
This item looks at ongoing IRS guidance.
When group policies are purchased from foreign insurance companies, there may be federal insurance excise tax issues.
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.
Starting this year, FBARs have a new, April 15 due date, with extensions to Oct. 15.
This article revisits the reporting requirements for an FBAR and highlights FBAR reporting requirements that differ from those of Form 8938.
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.
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).
The Treasury Department may soon experience relationship problems with certain countries that have entered into intergovernmental agreements under FATCA.
The regulations require specified domestic entities to report specified foreign financial assets in which they have interests.
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.
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 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.
The IRS finalized proposed regulations issued in 2011 that require reporting of specified foreign financial assets by specified domestic entities on Form 8938, Statement of Specified Foreign Financial Assets.
The IRS announced that the United States has entered into agreements with Australia and the United Kingdom implementing procedures to automatically exchange financial account information pursuant to the Foreign Account Tax Compliance Act (FATCA).
FATCA introduced a new reporting and tax withholding regime, effective July 1, 2014, that is directed at both foreign financial institutions and nonfinancial foreign entities to prevent tax evasion by U.S. citizens and residents through use of offshore accounts.
Individuals who are required to report interests in foreign financial assets to the IRS got guidance on the process in the form of final regulations. The regulations finalize temporary regulations issued in 2011, with some changes.
Financial institutions and tax administrators that have an obligation under U.S. tax law to report account information to the IRS now have a secure online site where they can transmit that information, the IRS announced.