Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
On September 19, 2025, the U.S. District Court for the Northern District of Texas upended IRS FBAR enforcement in United States v. Sagoo (No. 4:24-cv-01159, N.D. Tex. 2025). Sharnjeet Sagoo, a U.S. taxpayer with international ties, faced over $1 million in penalties for alleged willful failures of the Bank Secrecy Act requirement to report foreign … Continue reading The Sagoo Case: FBAR’s Reckoning In A Globalized World
Learn all about FBAR and expand services to your clients with confidence. Maybe even land Pope Leo XIV as a new client since his Holiness probably has to file FinCEN Form 114 for the Vatican Bank's accounts. Understand your own compliance risks and what to do if you are not compliant. This is the FBAR … Continue reading WEBINAR – Back By Popular Demand FBAR, FBAR, FBAR!
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
As most of my readers know the Corporate Transparency Act (CTA) requires US entities (including for example, US LLCs, corporations, partnerships), and many foreign entities including those that register to do business in a state, to disclose to FinCEN of the Treasury Department, the identity of their beneficial owners. Information to be provided: name, date … Continue reading Corporate Transparency Act: BEWARE! The Scammers have Already Arrived!
Digital assets and FBAR reporting are definitely on the horizon but as yet, have not arrived. With the various announcements by the Internal Revenue Service (IRS) that focus on the proper tax reporting for digital assets, as well as delaying implementation of third party broker reporting, it makes total sense that the Financial Crimes Enforcement … Continue reading Digital Asset Reporting for Mr. FBAR @FinCEN
On April 5th, the Financial Crimes Enforcement Network of the Treasury Department (FinCEN) issued an advance notice of proposed rulemaking (ANPRM) to solicit public comment on questions pertinent to the implementation of the "Corporate Transparency Act" (CTA), enacted into law as part of the National Defense Authorization Act for Fiscal Year 2021. The ANPRM seeks … Continue reading FinCEN Moving Quickly to Regulate Beneficial Ownership of US Entities
There’s a new law on the books and it does not bode well for, among others, those with foreign accounts that have not been properly reported to the Internal Revenue Service. The “Combating Money Laundering, Terrorist Financing, and Counterfeiting Act of 2019” (the “Act”) became part of the reconciled National Defense Authorization Act for Fiscal … Continue reading Your Foreign Bank Records – IRS Now Has Much Easier Access
It’s finally here! We now have a new law mandating creation of a national database of beneficial owners of US businesses (and foreign businesses registered to do business in the US). It’s been a long time in coming and is being hailed as a huge anti-corruption and anti-money laundering reform . There have been several … Continue reading Bye-Bye Shell Companies! Beneficial Ownership Reporting Now Required by the USA
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
Virginia - US TAX TALK 