When is a US taxpayer required to disclose offshore accounts on an FBAR and IRS Form 8938? While many US taxpayers and expatriates have come to understand the requirements of the FinCEN Form 114 or FBAR, a surprising number still need to understand the risk they are taking when they...
IRS Issues 2022 Dirty Dozen Scams Warning Including Crypto and Offshore Accounts
The IRS has issued a 2022 Dirty Dozen Scams warning including crypto and offshore accounts urging US taxpayers to be aware of “bogus tax avoidance strategies.” One of the most substantial buckets referenced in the report is an attempt to use offshore accounts or digital assets such as cryptocurrency in...
What are Disregarded Entities and How Does This Relate to an IRS FBAR?
What are disregarded entities and how does this relate to an IRS FBAR? There is a lot about "disregarded entities" in the news recently due to a recent ruling by the IRS in conjunction with offshore asset and income reporting and FBAR requirements. A disregarded entity has been the IRS'...
US Court of Appeals Upheld Requirement for IRS FBAR Reporting
The Sixth District of the US Court of Appeals upheld requirement for IRS FBAR reporting recently. The decision affirmed the actions of a US District Court which dismissed a complaint which challenged FATCA and the requirement to come into compliance with IRS FBAR disclosures. The lawsuit sought to prohibit...
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...
Argentina’s Offshore Amnesty Program Nets $5.2 Billion in Taxes
Argentinas offshore amnesty program nets $5.2 Billion in taxes after Argentinians disclosed over $90 Billion in previously hidden assets. Under the law Argentines could disclose offshore cash and assets to the government and pay a 10% tax. Argentine tax payers have an extension to disclose further offshore cash until the...
IRS Targets Bitcoin Transactions in Federal Case Here in California
There is an interesting case which has been filed in a California Federal Court. Concerns are mounting as the IRS targets bitcoin transactions through Coinbase, a bitcoin exchange, through the strategy of a "John Doe Summons." The IRS has used this strategy in the past in an attempt to force...
Brazilian FATCA Offshore Disclosures Net $4 Billion US
The deadline for Brazil's offshore account, income and asset reporting passed last week. The Brazilian Federal Revenue Secretariat (SRF) - Brazil's equivalent of the IRS - claims more than $4 Billion (US) in revenues from voluntary disclosures much like the US Offshore Voluntary Disclosure Program or OVDP. The Brazilian FATCA offshore...