If you have offshore accounts, investments or assets and have not come into compliance with the IRS, you should contact the San Diego FBAR attorneys at Allen Barron, who will provide guidance and insight into your options and help to ensure the best outcome in your case. Which voluntary disclosure...
US Justice Department Wins First FATCA Legal Victory – Shell Company and Its Nominees
Last week, the US Justice Department announced its first FATCA Legal Victory when it announced that Gregg R. Mulholland, owner of an offshore investment management company based out of Panama and Belize has plead guilty to money laundering and conspiracy. The firm was accused of fraudulent behavior, manipulating the value of...
US Taxpayers Identified in Panama Papers Should Immediately File OVDP
One thing is clear about the massive release of additional documents in the "Panama Papers" scandal yesterday: It's only a matter of time. There are several US taxpayers identified in yesterday's information release who should seriously consider their position and immediately file OVDP application to avoid potential criminal exposure for tax...
How Has the IRS FBAR Definition of “Non-Willful” Changed?
Why has the IRS questioned or outright rejected many of the applications under the Streamlined Domestic Offshore procedures? How has the IRS FBAR definition of "non-willful" changed? Previously the forms associated with the streamlined domestic offshore procedures (IRS Forms 14653 and 14654) simply asked the taxpayer to "provide specific reasons...
IRS Receiving Treasure Trove of US Taxpayer Offshore Account Information
The IRS reports that it is receiving a vast amount of offshore account information from foreign banks, investment institutions and sovereign tax authorities regarding US taxpayers. The information is quite detailed and linked to individual taxpayer IDs, and includes data such as account information, balances (present and historical), transactions as...
IRS Changes Streamlined Domestic Offshore Procedures Forms
The IRS has made significant changes to the forms associated with the Streamlined Domestic Offshore Procedures, a voluntary disclosure to the US government of offshore accounts, assets and income. The streamlined program was designated for US taxpayers who exhibited "non-willful" conduct in terms of why they failed to report offshore...
No Extension for June 30 FBAR Filing Deadline – Panama Papers Ruffle Feathers
There will be no extension to the June 30 FBAR filing deadline for US taxpayers who are required to file an IRS FBAR (Report of Foreign Bank and Financial Accounts). FBAR forms must be submitted electronically on or before June 30, 2016 for tax year 2015. Who must file an...
Improving Offshore Reporting and FBAR Compliance Top Priority for IRS
Improving offshore reporting and FBAR compliacne associated with foreign bank accounts, investments and income remains a top priority for the IRS according to IRS Commissioner John Koskinen. Commissioner Koskinen also said "Taxpayers here and abroad need to take their offshore tax and filing obligations seriously." What are those who continue to...
I Didn’t Know I needed to File an FBAR – Is That Non-Willful Conduct?
I hear it often - from dinner parties to fellow travelers to those who simply call for advice: "I didn't know I needed to file an FBAR." The next questions that follows are often: "This isn't that big of a deal is it? Can I simply catch up on my past FBARs and...