Tag Archive for FBAR

How The “Assistance In Collection” Provisions In The Canada-U.S. Tax Treaty Facilitates “U.S. Citizenship Based Taxation”

John Richardson

I commented on an article titled: “Why is the IRS Collecting Taxes for Denmark?” which appeared at the “Procedurally Speaking” blog. The article is about the “assistance in collection” provision which is found in 5 U.S. Tax Treaties (which include: Canada, Denmark, Sweden, France and the Netherlands). I am particularly interested in this because of a recent post at the Isaac Brock Society.

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Forms Required By #Americansabroad 101 – The Explanation

John Richardson BNN

The following is a response to comments made about an article written by Rachel Heller on titled, “Why I renounced my US citizenship (Hint: it’s not because I’m avoiding taxes!).” The article was well written, interesting and attracted responses from Homeland Americans. (It was reproduced here and attracted even more comments.) The comments from U.S. residents demonstrated again that they do NOT understand the problems experienced by Americans abroad.

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When Junior Has A Foreign Bank Account: What’s To Be Expected!

Manasa Nadig

I looked up my last blog post and realized I have not posted here since January! What a tax season it was, and how did time get away from me? Oh wait…I know how!

The past few years have seen a steady growth of a client base that has foreign accounts: no complaints there! Most clients have very routine FBAR filing requirements but then sometimes things are a little out of the ordinary and that gets me all excited…yes, I does! That either tells you about my lack of a life during tax season or we should just notch it up to tax nerd-iness!

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Is This Canadian Baby An American Tax Cheat?

Pati (3)

Is This Canadian Baby An American Tax Cheat?

A Canadian baby is learning about taxes, banking and activism at a tender age. The eight month old girl received a “Dear Valued Customer” letter from her Canadian bank when she was six months old advising her that her account information may be provided to Canada Revenue Agency to pass on to IRS.  The wee “Valued Customer” was directed to complete, sign and mail forms to the bank.

Baby Elle (not her real name) and her Canadian parents were Read more

Tax Considerations When Dealing With Foreign Transactions

Maurice Glazer

Tax Considerations When Dealing With Foreign Transactions

As a follow-up to questions, about tax considerations when dealing with foreign transactions , one of the big areas of concern is the area of foreign entities and the income effects that they have on our person tax returns. Controlled Foreign Corporations have a unique capability of delaying the paying of tax until the income is Read more

Cheap Shelf Or Top Shelf?


Many people make purchase decisions based on cost, and little else. “Motor oil is motor oil,” they insist. In the minds of many, it is pure folly to pay X dollars per month for auto insurance when another company provides the same service for a mere Y dollars. Or, they ask rhetorically, what moron would pay X dollars per gallon for gasoline when the station a quarter-mile down the road only charges Y dollars?

But, as the corporate shills at Valvoline were quick to remind Earl, cost is only one element in a purchase decision. As many of us Read more

FATCA 2015 Roundup: It’s All Serious Business!

TaxConnections Member Manasa Nadig

A lot has been written about the Foreign Account Tax Compliance Act {FATCA} in the past year. As this year comes to a close and I write up this post, I wanted to give you all, my dear readers a synopsis at your finger-tips, a round-up, if you will of some major FATCA events for 2015:

1. FBAR Deadlines Changed:

On July 31, 2015 President Obama signed the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 into law, which modified the due date of several key forms for Americans with foreign income and Americans living abroad. That includes the Report of Foreign Bank and Financial Accounts, or Form 114, colloquially known as the FBAR.

Any U.S. person with a financial interest in, or signatory authority over, foreign financial accounts must file the FBAR, if at any time, the aggregate value of their relevant foreign account or accounts exceeds $10,000. An account over Read more

Top Tax Blogs from 2015

Top Tax Blogs from 2015

During 2015 readers of TaxConnections Worldwide Tax Blogs arrived from more than 200 countries and spent an average of 12:45 during each visit. These are mighty numbers and they are due to the tax experts who joined our community and submitted their tax expertise and blog posts throughout the year.

We would like to congratulate our top tax blog contributors and link you to the top posts this year. We are grateful for the journey we made with you throughout the year and look forward to enjoying a successful 2016 with you.

Check out the top 20 Tax Blogs in 2015!

Story of A Good Citizen Who Reports Foreign Bank Accounts But Forgets FBARs! Huh? – Manasa Nadig

How To Live Outside The United States In An FBAR And FATCA World – John Richardson

Read This Before Tossing Old Tax Records – Barry Fowler

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It’s All In The Name


Some events are so seminal that they need no explanation. When someone says “Holocaust” or “9/11” or “Hindenburg,” no further explanation is needed. Some sports stars share similar fame. There is only one Michael, one LeBron, and one Wilt. While he admittedly does not rise to that level – some scouts shake their heads and say his left-handed layup needs work – James Moore’s rather commonplace name may someday reach that upper echelon.

Part I

A few months ago, I posted on the curious case of Moore v. United States. That article has an exhaustive discussion of the facts and also of FBAR. In a nutshell, Mr. Moore did not file an FBAR for 2003-2008; he filed late in 2009. The IRS conducted an investigation and sent Mr. Moore a memo in 2011 which curtly informed him that, after due Read more

Story of A Good Citizen Who Reports Foreign Bank Accounts But Forgets FBARs! Huh?

Manasa Nadig - 11-17-15

I have to say today’s blog post was triggered by a phone call a few weeks ago. The would-be client wanted to report his foreign bank accounts. Apparently, this good citizen had all his I’s dotted & T’s crossed – so to speak – so what was the problem you ask? I hate to say this, but it happens more than you would think. He did not know there were additional reporting requirements involved when it came to bank accounts in foreign financial institutions. (More on FBAR thresholds in my post here)

You have to know that the IRS will not impose a penalty for the failure to file the delinquent FBARs if you “properly” reported the foreign bank accounts on your US tax returns, and paid tax on the income from these accounts and have not been contacted by the IRS for an income tax examination or a request for the delinquent returns has not been made by them. Read more

Part 10 – Understanding “Exit Taxes”

John Richardson 19
The S. 877A “Exit Tax” and possible treaty relief under the Canada US Tax Treaty

Introduction – The Canada U.S. Tax Treaty Does Not Always Prevent Double Taxation

See: Part 9 – Understanding “Exit Taxes” – For #Americansabroad: US “citizenship taxation” is “death by a thousand cuts”, but the S. 877A Exit Tax is “death by the guillotine”.

When countries independently make major changes in tax law, double taxation can occur.

The following comment from 5thSwiss on the Isaac Brock Society site explains why and how double taxation can be a reality. It also underscores the dangers of a U.S. citizen leaving the United States. Read more