Want Protection from Criminal Prosecution for Tax Noncompliance? IRS Provides Only One Way

As many will remember, the Offshore Voluntary Disclosure Program (OVDP) closed on September 28 2018 with the promise that the Internal Revenue Service (IRS) would issue new guidance on voluntary disclosures made after that date.  The guidance arrived on November 20 2018 in the form of a 5-page Memorandum (IRS Memorandum LB&I-09-1118-014) (“Memorandum”) by the … Continue reading Want Protection from Criminal Prosecution for Tax Noncompliance? IRS Provides Only One Way

Wondering if You (or Your Clients) Need to File an FBAR or Have Been Preparing Them Correctly?

I will be making FBAR matters simple in a cost-effective live online training session along with my colleague, Jimmy Sexton, LL.M. a fellow international tax expert. Whether you are preparing your own FBARs or those of your clients, the truth is that some FBAR situations are simple and others are not. Learn everything you need … Continue reading Wondering if You (or Your Clients) Need to File an FBAR or Have Been Preparing Them Correctly?

No IRS! The Sky is NOT the Limit….MAJOR FBAR WIN! Penalty is Per FBAR Form, Not Per Account

As all my readers know, the Bank Secrecy Act (BSA) has been requiring US taxpayers to report certain foreign financial accounts and retain detailed records about them.  Failing to file or to properly report all foreign accounts on the notorious “FBAR” (FinCEN Form 114, Report of Foreign Bank and Financial Accounts) can result in very high … Continue reading No IRS! The Sky is NOT the Limit….MAJOR FBAR WIN! Penalty is Per FBAR Form, Not Per Account

Virtual Currency:  IRS Sheds More Light for 2020 Tax Returns

The US Internal Revenue Service (IRS) released instructions to the draft 2020 Form 1040 on Oct 23rd.   It may be recalled that a virtual currency question was introduced for the first time on the 2019 Form 1040 on Schedule 1. Not all taxpayers are required to complete Schedule 1. Now, the 2020 Form 1040 places the question … Continue reading Virtual Currency:  IRS Sheds More Light for 2020 Tax Returns

CONFUSED? FinCEN Blows it….FBAR Due Date Now Extended Till October 31 2020

On October 14, the Financial Crimes Enforcement Network (FinCEN) caused a lot of confusion for taxpayers and their advisors concerning the filing due date for foreign (non-US) financial accounts.  An incorrect posting was issued by FinCEN about the 2020 deadline to file Form 114, Report of Foreign Bank and Financial Accounts, commonly known as the … Continue reading CONFUSED? FinCEN Blows it….FBAR Due Date Now Extended Till October 31 2020

Seriously? IRS Assesses US$5.1 Million FBAR Penalty for “Signature Authority”

I have been keeping readers up to date with the current controversy surrounding imposition of an FBAR penalty for “willful” violations – is it limited to a $100,000 cap or can the penalty, if greater, be assessed at 50% of the value of the unreported account? More detailed background on this issue is available at my … Continue reading Seriously? IRS Assesses US$5.1 Million FBAR Penalty for “Signature Authority”

MAJOR FBAR WIN for the Taxpayer! Penalty is Per FBAR Form, Not Per Account

Since the early 1970’s the Bank Secrecy Act (BSA) has been requiring US taxpayers to report certain foreign financial accounts and retain detailed records about them.  Many individuals now know about the notorious “FBAR” (FinCEN Form 114, Report of Foreign Bank and Financial Accounts). It comes as a surprise to many, however, to learn that the … Continue reading MAJOR FBAR WIN for the Taxpayer! Penalty is Per FBAR Form, Not Per Account

FBAR “Willfulness” – Fifty Shades of Gray

It’s been awhile since I have blogged about our friend, Mr. FBAR.  For those of you who are not familiar with his nickname, you may know him by his more formal moniker “Report of Foreign Bank and Financial Accounts” (FinCEN Form 114).  He springs from Title 31 of the Bank Secrecy Act (not the Internal … Continue reading FBAR “Willfulness” – Fifty Shades of Gray