How does the IRS define willfulness in unreported or under-reported offshore income? What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct? Why should U.S. taxpayers be concerned whether the IRS perceives their actions as willful? If you have accounts with any Foreign Financial Institutions...
When to Consider the IRS Voluntary Disclosure Program
Are you wondering when a US taxpayer should consider the IRS Voluntary Disclosure Program or VDP? Are you concerned about unreported or under-reported income, financial accounts, assets, investments, cryptocurrency or business assets or interests? What do you need to know about FATCA-based reporting to the IRS and how the agency...
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...
Questions Regarding Offshore Accounts and FBAR Filing Requirements
Many US taxpayers still have questions regarding offshore accounts and FBAR filing requirements and compliance. Is there a genuine risk their activities (or lack of compliance) will come to light? The definition of a US taxpayer includes all US citizens, as well as those who work or live within the...
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...
Is This The End of the OVDP for IRS FBAR Disclosures
Is this the end of the OVDP for IRS FBAR disclosures regarding offshore bank accounts, investment accounts and assets? The IRS has in fact announced it will close the Offshore Voluntary Disclosure Program or OVDP on September 28, 2018. The IRS has strongly recommended that all US taxpayers, including resident...
The IRS Begins Accepting 2017 Tax Returns
The IRS begins accepting 2017 tax returns as tax season is upon us. Allen Barron is uniquely structured to prepare and file your international, domestic, business and personal tax returns. Our tax attorneys are supported by Allen Barron's accounting professionals as we work toward this year's deadline of April 17. ...
Ignorance of IRS FBAR Reporting is Not a Defense
Our offices have handled many cases recently of foreign nationals and spouses with offshore accounts and assets who were not aware of their IRS FBAR reporting requirements. Unfortunately ignorance of IRS FBAR reporting is not a defense and the IRS is ruthlessly pursuing huge penalties and interest for those who...
What are Willful Conduct and Willful Blindness in IRS FBAR Audits
What are willful conduct and willful blindness in IRS FBAR audits and court cases? It is important to begin with an understanding regarding IRS FBARs and when they are required. Any US taxpayer who has offshore bank or investment accounts (outside the United States) is required to prepare and file an...