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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...

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...

Argentina’s Aggressive Offshore Tax Strategy Results in Threat to Account Holders of Major US Bank

The implementation of global forms of the US FATCA tax initiative, often referred to as GATCA (Global FATCA) continue to gain steam in Central and South America.  This week a major US bank threatened to close the accounts of Argentinians with "undeclared funds."  JP Morgan announced this week that "all funds...