A request for public comment reveals the IRS is considering updates to the Voluntary Disclosure practice. The agency states its “commitment to improve its processes, and to further incentivize non-compliant taxpayers to come into compliance.” Key Takeaways Now That the IRS is Considering Updates to the Voluntary Disclosure Practice: The...
The IRS will Discover Your Offshore Financial and Digital Activities
As long as there have been taxes levied in the world, there have been those who try to work the system or evade taxes altogether. Unfortunately for many, the world has become a much smaller place for those who wish to underreport income or shelter their income and assets. The...
FBAR Requirements as a U.S. Person for an Offshore Account
What are your FBAR requirements as a U.S. person or taxpayer for an offshore account, group of accounts, property, or investment? The penalties associated with non-compliance with the reporting of offshore accounts, assets and income are quite severe. Primary Takeaways Regarding FBAR Requirements as a U.S. Person or Taxpayer With...
U.S. Taxpayers with Offshore Investments Should Be Wary of PFICs
U.S. taxpayers with offshore investments should be wary of PFICs (Passive Foreign Investment Company). Many foreign nationals live and work in the United States. For those who invest in offshore companies that generate income in a passive nature (i.e. rents, royalties, interest, income from commodities or derivative trading) are permanent...
US Taxpayers and Expatriates May Need to File Offshore Disclosures and FBARs
How many U.S. taxpayers and expatriates may need to file offshore disclosures and FBARs with the IRS? Should those who have not yet filed a disclosure application utilize the VDP (Voluntary Disclosure Program) or a streamlined application through the Streamlined Filing Compliance Procedures or SFCP? Many U.S. taxpayers have taken...
Offshore Real Estate Ownership and Tax Reporting Requirements
What do you need to know about offshore real estate ownership and any associated tax reporting requirements? Are you a U.S. taxpayer or U.S. resident who owns real estate outside of the United States? It may surprise you to learn that the U.S. and many individual states, including California and...
What is Willful Blindness According to the IRS?
What is willful blindness according to the IRS? How is this important in tax cases involving unreported or under-reported income, disclosure of offshore assets and income, FinCEN Form 114 (more commonly referred to as an "FBAR"), and even digital currencies and Non-Fungible Tokens (NFTs)? In an internal IRS memorandum from...
Is it Too Late to Correct Past FBARs and File Amended Returns with the IRS?
Is it too late to correct past FBARs and file amended returns with the IRS? The net is closing in on U.S. taxpayers with unreported or under-reported domestic and offshore income and assets. The IRS has increased audits in this area based upon a significantly improved ability to process data...
How Does the IRS Define Willfulness in Unreported or Under-reported Offshore Income?
How does the IRS define willfulness in unreported or under-reported offshore income? What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct? Why should U.S. taxpayers be concerned whether the IRS perceives their actions as willful? If you have accounts with any Foreign Financial Institutions...