The Internal Revenue Service (IRS) Streamlined Procedures of 2014 are still available for taxpayers with tax noncompliance issues that involve unreported income from a foreign financial asset. The Procedures can help taxpayers who have not filed certain information returns associated with the foreign asset (e.g., Form 8938; Form 5471 pertaining to ownership in a foreign … Continue reading Foreign Accounts and Assets: How I Approach a “Streamlined” Tax Filing Nowadays
Author: us-tax.org
US Supreme Court to Decide: FBAR Penalty, $10K per Form or per Account?
The US Supreme Court just agreed to resolve the split in the circuit courts whether the FBAR $10,000 civil nonwillful penalty is to be applied on a “per account” rather than “per form” basis. By granting certiorari to Mr. Bittner, a taxpayer who petitioned the Court to review his case, we will finally have a … Continue reading US Supreme Court to Decide: FBAR Penalty, $10K per Form or per Account?
Escaping the USA, Exit Tax and Transfer Tax Regimes: Using the “Dual National” Exception
Join me today in a live webinar: Everything you need to know about giving up a green card or US citizenship - 2 CPE credits. Register here. The economy is not looking good with the stock market dropping sharply, with tech companies being hit most dramatically, dropping by about 40%. Crypto markets are also in … Continue reading Escaping the USA, Exit Tax and Transfer Tax Regimes: Using the “Dual National” Exception
Think Like a Lawyer …. Is a Bear a Dog? Is a Bee a Fish? Well then, what’s an Assault Rifle?
Today's post is not a tax post. It's an email I sent to some of my former business law students who I had the pleasure to teach 15+ years ago at the American University of Sharjah and at the American University in Dubai, in the United Arab Emirates. I am in regular contact with many … Continue reading Think Like a Lawyer …. Is a Bear a Dog? Is a Bee a Fish? Well then, what’s an Assault Rifle?
Everything You Need to Know: “Expatriation”- Giving up a Green Card (LTR) or US Citizenship
Curious about what it means from a US tax perspective if you give up your green card or US citizenship? You really should know BEFORE you take the plunge and apply for that green card or obtain US citizenship. Tax pro's -- Want to expand your client reach by advising and planning with confidence about “expatriation”? … Continue reading Everything You Need to Know: “Expatriation”- Giving up a Green Card (LTR) or US Citizenship
US Residency “First Year Election” and FBAR – The Devil is in the Details
Recently, I presented a webinar for tax pro’s earning CPE credits; the topic involved our favorite character, Mr. FBAR. The FBAR, Form 114, is more formally known as the Report of Foreign Bank and Financial Accounts. The webinar will be available soon as a CPE credit "self-study" program. Send me an email if you wish … Continue reading US Residency “First Year Election” and FBAR – The Devil is in the Details
Solicitor General Wants US Supreme Court to Decide Whether the FBAR “Nonwillful” Penalty is “Per Form” or “Per Account”
My earlier blog posts discussed the split in the circuit courts whether the FBAR $10,000 civil nonwillful penalty is to be applied on a “per account” basis rather than “per form”. The crux of the matter involves conflicting statutory interpretations by the 5th and 9th circuit courts of the Bank Secrecy Act (BSA) (31 U.S.C. … Continue reading Solicitor General Wants US Supreme Court to Decide Whether the FBAR “Nonwillful” Penalty is “Per Form” or “Per Account”
FBAR – It Gets You in the End, Presidential Pardon Notwithstanding
Can a presidential pardon forgive FBAR penalties? Maybe Paul Manafort Jr. thinks so! Despite notice and demand for payment, he is not paying US$2.9 million in “willful” FBAR penalties assessed against him. The US government just brought an action in the southern district court (West Palm Beach division 4/28/2022), to collect the outstanding civil penalties … Continue reading FBAR – It Gets You in the End, Presidential Pardon Notwithstanding
Expatriation and Tax Compliance – IRS Fails to Process the Tax Return
As a tax practitioner I have assisted many taxpayers for decades with expatriation issues (i.e., relinquishing US citizenship or a green card held for at least 8 tax years). In the best case scenario, the taxpayer can avoid being treated as a "covered expatriate" (CE). Sometimes tax planning, correcting tax returns or submitting delinquent international … Continue reading Expatriation and Tax Compliance – IRS Fails to Process the Tax Return
Recent FBAR Case: IRS Seeks “Willful” Penalty $8.8M Without Much Regard for the Facts
A very recent FBAR case teaches us a few things. My colleague, attorney John Richardson, noted this after reading the case: "When charities need to raise money they will often have a bake sale or an auction. When the US government wants to raise money it uses an 'FBAR Fundraiser'". Readers, draw your own opinion! … Continue reading Recent FBAR Case: IRS Seeks “Willful” Penalty $8.8M Without Much Regard for the Facts