Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
Yesterday, the world welcomed Pope Leo XIV, a U.S. citizen, as the newly elected Pope, marking a historic moment for the Catholic Church. But amid the papal fanfare, a quirky tax question arises: could His Holiness need to file a Report of Foreign Bank and Financial Accounts (FBAR) for the Vatican Bank’s accounts? It’s a … Continue reading Does Pope Leo XIV Have to File an FBAR? U.S. Citizenship and God’s Bank
A recent decision reminds taxpayers and the tax compliance community of the importance of filing the Report of Foreign Bank and Financial Accounts. The U.S. District Court for the Southern District of New York in United States v. Hendler, 23 Civ. 3280 (Sept. 17, 2024) has clarified the enduring nature of penalties tied to FBAR. … Continue reading The Hendler Case: FBAR Penalties Survive Beyond Death
As the April 15 tax filing deadline approaches, U.S. persons with foreign financial accounts must be aware of their obligation to file the Report of Foreign Bank and Financial Accounts, commonly called the “FBAR”. The filing deadline is April 15, the same due date as one’s U.S. income tax return, but there is an automatic … Continue reading FBAR Due Date: Triggers And Key Compliance Rules For U.S. Taxpayers
The process for IRS to seize foreign assets to satisfy tax debts is not simple. IRS use of the so-called John Doe summons is often a first step to identify possible tax evasion with offshore assets, as noted in the recent case involving Trident Trust. After resolution of the tax matter, the IRS is faced … Continue reading Cross-Border Tax Collection: IRS Tools To Seize Foreign Assets
The Department of Justice and the Internal Revenue Service have recently reaffirmed their strong commitment to pursuing offshore tax evasion through the use of powerful investigative tools. One such tool is the IRS John Doe Summons. On Dec. 23, 2024, the United States District Court for the Southern District of New York granted the IRS authority … Continue reading Offshore Tax Evasion: U.S. Clients Of Trident Trust Target Of IRS John Doe Summons
Roger Ver, an early Bitcoin investor renowned as “Bitcoin Jesus” for his evangelism of cryptocurrency since 2011, now finds himself in a legal maelstrom. Ver, a controversial figure in the blockchain world, was arrested in April 2024 in Spain on U.S. criminal charges stemming from allegations of mail fraud, tax evasion, and filing false tax … Continue reading Bitcoin Jesus Challenges Constitutionality Of Expatriation “Exit Tax”
The Financial Crimes Enforcement Network, FinCEN Form 114, Report of Foreign Bank and Financial Accounts, is a crucial yet frequently misunderstood requirement for U.S. persons with foreign financial accounts. The FBAR may be familiar to many Americans living abroad, but it remains largely unknown to many U.S.-based individuals who might still have an obligation to … Continue reading Cracking The Code On FBAR Penalties: IRS Collection Hurdles Explained
A recent decision from the 11th Circuit in United States v. Isac Schwarzbaum brings a major development in FBAR (Foreign Bank Account Reporting) penalties and their relationship with the Eighth Amendment's Excessive Fines Clause. The court's holding that FBAR penalties are subject to this constitutional protection under the Excessive Fines Clause is significant, offering taxpayers … Continue reading 11th Circuit Holds FBAR Penalties Are Subject to the Excessive Fines Clause: A Significant Taxpayer Weapon
Many taxpayers, especially retirees living abroad, may find themselves in a situation in which their income is too low to meet the threshold for filing a U.S. tax return. Retirees who only receive Social Security income (or small amounts of other additional income), for example, often fall below the tax filing requirement. Understandably, many people … Continue reading Filing A U.S. Tax Return – Even When Not Required – A Very Smart Move
My article copied below first appeared on Forbes July 12, 2024 – link here. You can follow me on Forbes for free. ~~~~~ The June 20, 2024 report by the Treasury Inspector General for Tax Administration came as a shock to many. The TIGTA report explained that to meet an audit quota set in 2020, … Continue reading IRS Increased Audits Of The Rich: A Flop In Finding Noncompliance
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