What are the risks and penalties of the failure to make a full disclosure of offshore accounts to the IRS? What happens if you have not included all of your offshore bank accounts, assets, investments, foreign trust and foreign corporate ownership interests to the IRS via FBAR or associated IRS...
Are You a Foreign National Living and Working in San Diego
Are you a foreign national living and working in San Diego? Have you come into the US on an H1-B or other Visa? It is important for all foreign nationals who reside in the US for more than a few months to understand their obligations under US tax laws. One...
Could the New Tax Bill Allow Repatriation of Offshore Funds
Could the new tax bill allow repatriation of offshore funds at a lower tax rate? It is believed that US non-financial companies have almost $2 Trillion (yes, Trillion with a "T") and 70% of that money is located overseas as US corporations structured companies and transactions to move income to...
The IRS Will Never Know About My Offshore Financial Accounts
We often hear clients say "The IRS will never know about my offshore financial accounts and assets," with conviction as if they are wishing it to be true. Unfortunately, the reality of today's world is much different. The truth of the matter is shocking to many people: The IRS is...
Does Your Domestic Entity Have Foreign Assets
Does your domestic entity have foreign assets which must be reported on the IRS Form 8938? The Foreign Account Tax Compliance Act or FATCA requires many US corporations, LLCs, trusts and partnerships which hold foreign investments or financial assets to disclose them on the form 8938. If a US trust...
IRS is Closing In on US Taxpayers with Offshore Accounts
The IRS is closing in on US taxpayers with offshore accounts thanks to the global exchange of information which has been a by-product of FATCA and the Justice Department's pursuit of Swiss banking and financial interests. The deal between the IRS and Swiss institutions ultimately led to an agreement to...
IRS FBAR Audits are Heating Up as Offshore Banking Information Pours In
IRS FBAR audits are heating up as offshore banking and taxpayer information pours into the IRS from offshore banks, financial institutions, investment houses and foreign sovereign tax agencies. The IRS formed agreements with most of the nations around the world as well as hundreds of thousands of banks, investment houses...
The US Tax Impact of Opening a Foreign Account
What is the US tax impact of opening a foreign account for a US taxpayer including foreign nationals who live and work in the United States? The requirement for US taxpayers to report offshore accounts has been around for quite some time. In 2004, the IRS added penalties for non-willful...
Wall Street Journal Warns Offshore Account Holders to Fear the IRS
A major US financial newspaper today echoed Allen Barron's repeated warnings to offshore account holders to fear the IRS and impending IRS audits. The Wall Street Journal (WSJ) today issued a daunting warning to US taxpayers with offshore bank accounts, investment accounts and assets: "Are You Hiding Money Overseas from...