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...
What is an FBAR and What Foreign Financial Information Are You Required to Report?
What is an FBAR, and what information is a U.S. taxpayer required to report to the U.S. Government and the IRS? There are many questions about the requirements for U.S. taxpayers with foreign accounts, investments, and assets, as well as the exchange of financial information between the IRS and Foreign...
When to Consider the IRS Voluntary Disclosure Program
Are you wondering when a US taxpayer should consider the IRS Voluntary Disclosure Program or VDP? Are you concerned about unreported or under-reported income, financial accounts, assets, investments, cryptocurrency or business assets or interests? What do you need to know about FATCA-based reporting to the IRS and how the agency...
IRS Updated Streamlined Filing Compliance Procedures
What do you need to know about the IRS updated Streamlined Filing Compliance Procedures or "Streamlined Procedures?" Are you concerned about unreported or under-reported offshore income or assets? Are there accounts you have inadvertently left off of a recent FBAR? Have you failed to file an FBAR when you otherwise...
Questions Regarding Offshore Accounts and FBAR Filing Requirements
Many US taxpayers still have questions regarding offshore accounts and FBAR filing requirements and compliance. Is there a genuine risk their activities (or lack of compliance) will come to light? The definition of a US taxpayer includes all US citizens, as well as those who work or live within the...