A new IRS Large Business & International (LB&I) campaign targets US taxpayers for IRS audits focused upon OVDP declines and withdrawls from the FBAR related program. Once the IRS implemented FATCA based regulations and the associated Foreign Bank Account Reporting (FBAR) requirements US taxpayers were required to disclose all offshore...
High Profile Trial May Shed Light on Willful Conduct in IRS FBAR Cases
A Pennsylvania Court has denied motions by both parties to dismiss a high profile trial which may shed light on willful conduct in IRS FBAR cases for US taxpayers. The CEO of a pharmaceutical company was accused by the IRS of willful failure to disclose Swiss bank accounts on his...
IRS FBAR Compliance for Canadian and Mexican Nationals in the US
If you live or work in the United States it is your responsibility to understand tax laws. This is why Allen Barron has been a leader in IRS FBAR compliance for Canadian and Mexican nationals living and working in the US. Many foreign nationals who reside or work here in...
A Reminder that IRS FBAR Reporting is Due Along with Your Tax Return This Year
Just a reminder that your IRS FBAR reporting is due along with your tax return on April 18th this year. The Foreign Bank Account Reports (referred to as FBAR) have previously been due later in the year, but 2017 marks a permanent change going forward. US taxpayers, including foreign nationals...
IRS Focusing on Transfer Pricing and Offshore Earnings says Wall Street Journal
In a recent article the Wall Street Journal warned that the IRS had released information about 13 "campaigns" to target high-value tax returns for IRS audit. The IRS intends to focus upon and international businesses transfer pricing and offshore earnings and the compliance with IRS FBAR reporting and offshore account...
The IRS OVDP May Still be a Viable Option for Unreported Offshore Accounts
There is a lot of conversation nationally about IRS FBAR compliance and those who have not yet complied. Many US taxpayers may be wondering if the IRS OVDP may still be a viable option for unreported offshore accounts and assets. The answer is a qualified "yes." The reality is the...
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...
IRS Launches New Campaigns to Focus Vertical Market Expertise on Tax Revenue Generation
The IRS launches new campaigns to focus vertical market expertise on tax revenue generation and compliance. Each "campaign" aligns internal IRS expertise on specific issues with the goal of "focused examination" (read: audit) on targeted matters. What are the 13 business related IRS audit campaigns and how will they affect...
Updates on Offshore Investments and IRS FBAR Reporting Requirements
The world is still unpacking the impact of FATCA and the IRS' intent to track offshore bank accounts, investments and corporations. The result is continuing pressure on offshore investments and IRS FBAR reporting requirements including PFIC tax calculations and the continuing expansion of 50% penalties on specific institutions identified by...