Taxpayers with undisclosed offshore accounts would be wise to take advantage of the lesser known IRS voluntary disclosure process.
Financial institutions need to remain vigilant and periodically update their compliance systems to ensure they remain fully compliant with the law.
FinCEN issued its annual reminder of the due date for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts.
The IRS published a FATCA FAQ to establish a temporary standard of independence until it can provide comprehensive guidance.
This article alerts the practitioner to when an information return may be necessary.
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 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 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 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.