Foreign nationals living and working in California—particularly in cities like San Diego, Los Angeles, San Francisco, and San Jose (Silicon Valley)—are often surprised by how quickly U.S. tax obligations can apply. Whether you entered the United States on an H-1B visa, L-1 visa, O-1 visa, or another employment-based visa, it...
IRS Updated Streamlined Filing Compliance Procedures
What do you need to know about the IRS updated Streamlined Filing Compliance Procedures or "Streamlined Procedures?" Are you concerned about unreported or under-reported offshore income or assets? Are there accounts you have inadvertently left off of a recent FBAR? Have you failed to file an FBAR when you otherwise...
When is a US Taxpayer Required to Disclose Offshore Accounts on an FBAR and Form 8938
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...
Federal Court Finds Willful Failure to File FBAR is a Lesser Standard of Proof for the IRS
The US 9th District Court here in California has found that willful failure to file FBAR is a lesser standard of proof for the IRS to bear. The Court rejected the claims of the defendant in the case that the IRS is held to a higher standard of proof -...