We have been at the forefront of the IRS crackdown on offshore bank accounts, foreign investments and corporate ownership and the requirement for US taxpayers to come into compliance with FBAR reporting and associated IRS offshore voluntary disclosures. For those who have decided to file IRS voluntary offshore disclosures under the...
Do All IRS FBAR Filers Need to Consider a Voluntary Disclosure or OVDP?
Yesterday, we discussed the rapidly rising number of “Report of Foreign Bank and Financial Reports” or FBARs filed in 2015. This continues a five year rising trend, and demonstrates the number of US taxpayers with offshore bank accounts and international investments. It also leads to a serious question for FBAR filers:...
Record Number of FBARs Filed in 2015 – up 8% over 2014
The IRS has reported that the number of "Report of Foreign Bank and Financial Reports" or FBARs filed in 2015 is up by more than 8 percent over 2014. A staggering 1,163,229 FBARs were filed with the IRS, continuing the trend of an increasing number of US taxpayers filing the...
IRS Adds Banks to the List of 50% OVDP Penalty Institutions
The IRS continues to add more and more international banks, financial and investment firms to its list of 50% OVDP penalty institutions each month. The list is based upon the IRS' determination that the bank or institution has actively helped US taxpayers to shelter income or avoid paying US taxes....
This is the Last Year FBARs will be Due to the IRS by June 30
This is the last year that the Report of Foreign Bank and Financial Accounts, or FBAR, will be due to the IRS on June 30 (for tax year 2015). When filing an FBAR for this calendar tax year, 2016, it will be due earlier than previous years - April 15, 2017. This is...
IRS Adds 7 More Swiss Banks to 50% OVDP Penalty List
The IRS has added 7 more Swiss banks to the 50% OVDP Penalty List in December, and now more than 100 Swiss banks are providing information about US taxpayers accounts and transactions directly to the IRS. For those US taxpayers who have already come into FBAR compliance with the IRS...
Why Should US Taxpayers With Offshore Accounts and Assets Be Cautious When Considering the Streamlined Domestic Offshore Procedures?
Why shouldn't every US taxpayer with offshore accounts or assets choose the Streamlined Domestic Offshore Procedures when coming into compliance with the IRS and FBAR reporting requirements under FATCA? Why wouldn't a US taxpayer simply want to claim "non-willful" conduct in their disclosures of offshore bank accounts, investments and assets...
Landmark Case May Help to Determine Willful vs Non-Willful Offshore Conduct – Swiss Man Sues IRS
In what is potentially a landmark lawsuit regarding the reporting of offshore accounts and assets to the IRS through FBAR and other forms, a Swiss man has filed a lawsuit against the IRS disputing "willful" versus "non-willful" behavior. It is interesting to note that this man, Bernhard Gubser, left one...
Quiet FBAR Disclosures Are Not What the IRS is Looking For
The IRS has been quite clear in recent publications that a "quiet" disclosure of offshore bank accounts and assets not previously reported on appropriate FBAR or Form 8938 is not enough to come into compliance. The OVDP is the option that presents the least risk to US taxpayers. The two...