A new IRS Large Business & International (LB&I) campaign targets US taxpayers for IRS audits focused upon OVDP declines and withdrawls from the FBAR related program. Once the IRS implemented FATCA based regulations and the associated Foreign Bank Account Reporting (FBAR) requirements US taxpayers were required to disclose all offshore...
Jan Allen to Speak on IRS FBAR and Willfulness
On October 11, 2017 from noon to 2:00 pm pacific time, Jan Allen will speak on IRS FBAR and willfulness during a live webcast entitled: "Willfulness and the IRS Disclosure Programs: Are You Compliant?" The program will answer the questions of US taxpayers and foreign nationals who live and work...
High Profile Trial May Shed Light on Willful Conduct in IRS FBAR Cases
A Pennsylvania Court has denied motions by both parties to dismiss a high profile trial which may shed light on willful conduct in IRS FBAR cases for US taxpayers. The CEO of a pharmaceutical company was accused by the IRS of willful failure to disclose Swiss bank accounts on his...
IRS FBAR Compliance for Canadian and Mexican Nationals in the US
If you live or work in the United States it is your responsibility to understand tax laws. This is why Allen Barron has been a leader in IRS FBAR compliance for Canadian and Mexican nationals living and working in the US. Many foreign nationals who reside or work here in...
A Reminder that IRS FBAR Reporting is Due Along with Your Tax Return This Year
Just a reminder that your IRS FBAR reporting is due along with your tax return on April 18th this year. The Foreign Bank Account Reports (referred to as FBAR) have previously been due later in the year, but 2017 marks a permanent change going forward. US taxpayers, including foreign nationals...
Postmortem Tidbits from the Panama Papers
It's been more than a year since the international "Panama Papers" scandal hit where 11.5 million documents disclosed the true owners of more than 214,000 offshore "shell" companies. Postmortem tidbits from the Panama Papers provide insight into the genuine risks offshore investors, international businesses, US expats, and foreign nationals living...
Record Number Renounce Their US Citizenship in 2016 Due to US Taxation of Worldwide Income
The US Treasury Department published the latest list of those who renounced their US citizenship in 2016. The recent spike in renounced citizenships has been tied to US taxation of worldwide income for all US residents and taxpayers. 5,411 individuals renounced their US citizenship in 2016, and while this may...
Updates on Offshore Investments and IRS FBAR Reporting Requirements
The world is still unpacking the impact of FATCA and the IRS' intent to track offshore bank accounts, investments and corporations. The result is continuing pressure on offshore investments and IRS FBAR reporting requirements including PFIC tax calculations and the continuing expansion of 50% penalties on specific institutions identified by...
Israeli High Court Rules US Citizens in Israel Must Comply with FBAR
The Israel Supreme Court ruled that US citizens in Israel must comply with FBAR and all IRS reporting requirements and the consequences of FATCA. Israeli banks, investment houses and financial institutions have already begun to report the detailed personal and financial balance and transaction information regarding the "beneficial ownership interest"...