Do You Have Foreign Life, Sickness, or Casualty Insurance? A Foreign Annuity Contract? Excise Tax / FBAR / Form 8938….

Many US persons living abroad have foreign life, sickness or accident insurance or a foreign annuity. Yet, only a handful have any knowledge of the US Foreign Insurance Excise Tax provisions affecting these policies.  Foreign asset information reporting may also apply.  Here's what you need to know! Foreign Life Insurance Generally, an excise tax of … Continue reading Do You Have Foreign Life, Sickness, or Casualty Insurance? A Foreign Annuity Contract? Excise Tax / FBAR / Form 8938….

Dubai (and Singapore) – Now IRS Targets for Offshore Investigations

Americans in Dubai / Singapore – If you are not tax compliant, time is really running out.  As reported by Bloomberg on March 8th, an official with the Internal Revenue Service (IRS) Criminal Investigation (CI) unit announced at a Washington DC Federal Bar Association event that CI is considering Dubai and Singapore as its "next … Continue reading Dubai (and Singapore) – Now IRS Targets for Offshore Investigations

IRS Hits the Jackpot: Another District Court Rejects $100,000 Cap on FBAR Penalty

I have been keeping readers up to date with the current controversy surrounding imposition of an FBAR penalty for “willful” violations. Here’s an overview of where we are to date. “Willful” Penalty Ceiling: The Cases So Far Last year, two district courts had limited the FBAR “willfulness” penalty to $100,000 because the Department of Treasury did … Continue reading IRS Hits the Jackpot: Another District Court Rejects $100,000 Cap on FBAR Penalty

Happy New Year – US to be Blacklisted as a Tax Haven?

Bloomberg reports that next year, the US may be put on the Organization for Economic Cooperation and Development’s (OECD) “blacklist” of tax haven countries alongside such notables as Guam and Trinidad and Tobago.  The move comes as numerous countries continue to question the United States’ adamant refusal to participate in the international information exchange program, … Continue reading Happy New Year – US to be Blacklisted as a Tax Haven?

It’s Finally Here: The IRS Bible for Voluntary Disclosures

As many will remember, the Offshore Voluntary Disclosure Program (OVDP) closed on September 28th with the promise that the Internal Revenue Service (IRS) would issue new guidance on voluntary disclosures made after that date.  The guidance just arrived in the form of a 5-page Memorandum by Kristen B. Wielobob, Deputy Commissioner for Services and Enforcement, … Continue reading It’s Finally Here: The IRS Bible for Voluntary Disclosures

Newest Targets: “Enablers” and “Cryptocurrencies”

Over the summer, I blogged about the newly formed “Joint Chiefs of Global Tax Enforcement”, or the “J5”, for short.  Five countries form this international coalition: Australia, Canada, the Netherlands, the United Kingdom, and the United States.   The goal of the J5 is to combat transnational tax crime through increased collaboration; in other words, these … Continue reading Newest Targets: “Enablers” and “Cryptocurrencies”

Before You Think of Becoming an “American Abroad”, Read This….

I was recently asked about the tax problems faced by Americans who move overseas.  Unfortunately, there are many US tax difficulties faced by Americans abroad. In order to make some sense of this vast topic, let's put the major problems into several basic categories.  Once aware of the problems lurking out there, you can get … Continue reading Before You Think of Becoming an “American Abroad”, Read This….

Recent Case “Willful” FBAR Penalty: Even Death is No Escape!

In a recent FBAR case involving an unreported foreign account maintained at none other than UBS in Switzerland, the court was called upon to decide whether the FBAR civil “willful” penalty assessed against the taxpayer survived his death.  The case is United States v. Schoenfeld (Middle District, Fla. 3:16-cv-1248-J-34PDB), dated 9/25/18, and the court order … Continue reading Recent Case “Willful” FBAR Penalty: Even Death is No Escape!

FORM 8938: Infinite Statute of Limitations & Everything Else You Need to Know

My prior blog post gave details about how the Form 8938, an important “Foreign Account Tax Compliance Act” (FATCA) enforcement weapon, is currently failing.  IRS enforcement efforts are soon on the upswing.  This is because the Treasury Inspector General for Tax Administration issued a report over the summer pointing out the IRS' failures with regard … Continue reading FORM 8938: Infinite Statute of Limitations & Everything Else You Need to Know