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...
US Has Now Reached FATCA Agreements with 75 Swiss Banks
An agreement reached just before Christmas means that the US has reached FATCA agreements with 75 Swiss banks. The US Department of Justice has confirmed penalties exceeding $178 Million from 4 Swiss bank agreements including: Banque Cantonal du Valais (BC Valais) Gonet & Cie or simply Gonet Bank J. Safra...
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...
Over 100 Swiss Banks Have Accepted US FATCA Deal – FBAR Foreign DIsclosures Increasing
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Thursday, December 17, 2015. The IRS recently announced the addition of several foreign banks and institutions to its list of 50% OVDP penalty institutions. These banks have been found by the IRS to help US taxpayers...
Over 177,000 Offshore Banks and Institutions Providing Financial Information to the IRS
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Wednesday, December 2, 2015. The IRS has announced that FATCA agreements have led to the exchange of financial information regarding US taxpayers with 177,147 institutions in more than 200 sovereign nations and legal jurisdictions. The list...
Willful Versus Non-Willful Designation Left Intentionally Vague by IRS?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Thursday, December 3, 2015. We are often asked for a definition of "willful" versus "non-willful" activity by a US taxpayer as it relates to the disclosure of offshore assets, accounts and interests. The exact criteria for...
IRS FBAR Penalties for Willful and Non-Willful Conduct
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Wednesday, October 21, 2015. If you have a combined total of more than $10,000 in offshore bank accounts, assets or investments you are required to file an FBAR or Foreign Bank Account Report with the IRS...