Archive for FBAR

South African Tax Man’s Message To HSBC Account Holders

The South African Revenue Service (SARS) has announced an amnesty of sort – a threat and upfront warnings: we do know about you, best you come forward before we make the tax audit into your affairs known.

On July 9th, 2015, SARS issued a press release, which can be read in more detail on:

http://www.sars.gov.za/Media/MediaReleases/Pages/9-July-2015 – – – South-Africans-with-accounts-and-investments-in-foreign-tax-jurisdictions.aspx

The International Consortium of Investigative Journalists (ICIJ), based information obtained by French newspaper Le Monde, ranked South Africa number 31 among the countries with the largest amount of dollars ($2.3blion) in the so-called leaked Swiss Read More

Written by | Posted in Africa • Expatriate • FATCA • FBAR • Income Tax • International • IRS • OECD • OVDP • Swiss Bank Accounts • Tax Controversy • Tax Fraud/Evasion/Crimes • Tax Policy • Tax Provision/Tax Reporting • Tax Risk Management • Transfer Pricing • United States

Spotlight On Expatriate Tax Experts – September 21st 2015 – Internet Tax Summit

With an estimated 8.7 Million expatriates living around the world, many are unaware of their U.S. tax filing obligations. For those following the issues surrounding FATCA, they are well aware that expatriates are angry and scared. For the two-thirds of the U.S. expatriates who are still unaware, we bring knowledgeable experts who will explain what is happening and get you up to date at the Internet Tax Summit scheduled September 21-25th 2015. The first day of the Internet Tax Summit, expatriates will be able to go online and learn what is happening from tax experts, get answers, and get the help they need.  You can expect this historical, free online event is certain to get millions of expatriates up to speed on the only country in the world with citizen based taxation. We promise the information you learn will be STUNNING! Read More

Written by | Posted in Estate Planning Tax • Europe, Middle East • Expatriate • FATCA • FBAR • Internet Tax Summit - 2015 • OECD • OVDP • Tax Policy • TaxConnections

Take What They Give You

The first half of Super Bowl XX between the Chicago Bears and New England Patriots is painful to watch, for everyone except die-hard fans of Da Bears. Chicago looked like it was playing fifteen guys on defense, and all of them were at or near the line of scrimmage.

Several weeks earlier, the Miami Dolphins provided the perfect blueprint for beating the seemingly un-beatable Bears: quick passes to outside receivers. But New England quarterback Tony Eason kept employing slow-developing pass plays to backs and tight ends. The result wasn’t pretty. For some reason, New England coach Raymond Berry eschewed a fundamental principle in offensive football tactics, to-wit, “take what the defense gives you.”

Read More

Written by | Posted in FBAR • Tax Fraud/Evasion/Crimes

June 30th Filing Deadline for Foreign Reporting is Approaching Fast!!

Taxpayers With Foreign Assets May Have FBAR And FATCA Filing Requirements In June

WASHINGTON—The Internal Revenue Service today reminded all taxpayers with an FBAR filing requirement to report their foreign assets by the June 30 deadline. FBAR filings have risen dramatically in recent years as FATCA phases in and other international compliance efforts have raised awareness among taxpayers with offshore assets.

The IRS encourages taxpayers with foreign assets, even relatively small amounts, to check if they have a filing requirement. Separately, certain taxpayers living abroad may also have to file the FATCA-related Form 8938 with their tax returns by the June 15 Read More

Written by | Posted in FATCA • FBAR

Red Card

Ever since the United States hosted the World Cup Finals in 1994, soccer has struggled to find a place in the overwhelmingly crowded American sports landscape. So, if you subscribe to the theory that there’s no such thing as bad publicity, the recently-unsealed indictments in New York may be the best thing to happen since internationally-renowned striker and noted metrosexual David Beckham joined the Los Angeles Galaxy in 2007.

The indictments certainly weren’t good news for the 14 people named in the court documents; six of which have already entered guilty pleas. The list is a veritable who’s who at Fédération Internationale de Football Association (FIFA) and Confederation of North, Central American and Caribbean Association Football (CONCACAF). Of particular note to fans are the allegations that these FIFA luminaries accepted blood money in Read More

Written by | Posted in FATCA • FBAR • IRS • Tax Fraud/Evasion/Crimes

4 More Banks Reach Resolutions With U.S. Government For NPAs

On May 28, 2015, the Department of Justice announced the addition of four banks to its Swiss Bank Program. They are as follows:

• Société Générale Private Banking (Lugano-Svizzera)

• MediBank AG

• LBBW (Schweiz) AG

• Scobag Privatbank AG

For those unfamiliar with the Department of Justice’s Swiss Bank Program, a slight digression may be in order. The Swiss Bank Program was unveiled on August 29, 2013. Read More

Written by | Posted in FBAR • Tax Fraud/Evasion/Crimes

IRS Issues Updated Guidance For FBAR Penalties

The IRS recently issued a memorandum entitled, “Interim Guidance for Report of Foreign Bank and Financial Accounts (FBAR) Penalties.” As explicitly stated in the memorandum, its purpose is to improve the administration of the IRS’s FBAR compliance program. How so? By implementing new procedures. This guidance affects two specific IRMs: 4.26.16 and 4.26.17.

For those who thought that the IRS might have waited a couple months before making these procedures effective so as to allow tax practitioners sufficient time to get up to speed and to work out any “kinks,” that was wishful thinking. Far from enacting a “grace period,” these new procedures went into effect the very day they were published, which just so happened to be May 13, 2015. Thus, this guidance is effective immediately and Read More

Written by | Posted in FBAR • IRS

Making Citizenship-Based Taxation Reform Easy

Making Citizenship-Based Tax Reform “Easy”

Heitor David Pinto wants to “make it easy” for Congress to move from citizenship-based taxation (CBT) to residence-based taxation (RBT).

Pinto thinks CBT is “absurd.” And he aims to help Congress change it.

Because of CBT’s complexity and because it’s a low priority for Congress, Pinto was concerned Congress might take a long time or might not do tax reform at all for Americans abroad.  But, Pinto hopes “if it’s mostly done already, they might do it faster.”

When the naturalized American citizen immigrated to the United States from Brazil a Read More

Written by | Posted in Expatriate • FATCA • FBAR • Individual • International • IRS • Tax Provision/Tax Reporting

OVDP & Double Counting: Traps For The Unwary

Accounting for “double counting” is not child’s play. Your tax attorney will need the following information in order to complete his or her review of your double counting issue. These steps must be repeated for every year in which you believe that there is a double counting issue.

For each transfer, you should provide the following:

(a) The highest balance of the account from which the transfer(s) was made for the tax year in question;

(b) The highest balance of the account into which the transfer(s) was made for the tax year in question; Read More

Written by | Posted in FBAR • OVDP

Roll On One

James Moore received a temporary reprieve from a federal judge in Seattle, but, at least metaphorically speaking, he is still strapped onto the mercy seat in classic John Coffey style, waiting to see what the onlooking guards will do next. (See Video Clip Below)

No one really knows how Moore v. United States will turn out. What we do know is that, in a preliminary ruling, Judge Richard Jones declared that the IRS cannot spin the Wheel of Misfortune and arbitrarily determine the amount of a civil penalty in a Report of Foreign Banks and Financial Accounts (FBAR) failure to file case. The Service may well simply add to the record, and if that is the case, Judge Jones’ next order will be “roll on two.” However, there is a very good chance that this evidence does not exist, and in this alternative ending, an emotional Paul Edgcomb will quietly escort Mr. Moore out of the death house. Read More

Written by | Posted in FBAR
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